In three separate letters, SIFMA and six other financial industry associations filed comments with the Office of the Comptroller of the Currency ("OCC"), the Board of Governors of the Federal Reserve System ("FRB") and the Federal Deposit Insurance Corporation ("FDIC") (collectively, the "Federal Agencies") on the proposed rules regarding the liquidity coverage ratio ("LCR"). The letters contained comments on the LCR proposal in connection with international standards, securitization and municipal securities. In the first letter (linked below), SIFMA, the Structured Finance Industry Group (
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Deputy Comptroller for Compliance Operations and Policy, Grovetta Gardineer asserted that the OCC has taken steps to supervise and enforce better treatment of members of the armed forces under the Servicemembers Civil Relief Act of 2003 ("SCRA") and under amended rules implementing the Military Lending Act ("MLA"). In a speech delivered before the Association of Military Banks of America, Ms. Gardineer discussed OCC directives to banks to improve SCRA-compliance policies and procedures. She also discussed the expanded coverage of MLA rules under recent Department of Defense final amendments
The Consumer Financial Protection Bureau, the Board of Governors of the Federal Reserve System and the Office of the Comptroller of the Currency announced that the threshold for exempting loans from special appraisal requirements for higher-priced mortgage loans during 2016 will remain at $25,500.
Five federal agencies ("the Agencies") published interim and final rules on margin and capital requirements for registered swap dealers, major swap participants, security-based swap dealers and major security-based swap participants. The Office of the Comptroller of the Currency ("OCC"), the Board of Governors of the Federal Reserve System ("FRB"), the Federal Deposit Insurance Corporation ("FDIC"), the Farm Credit Administration ("FCA") and the Federal Housing Finance Agency ("FHFA") published the rules in the Federal Register. The final rule implements Dodd-Frank Sections 731 ("Registration