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A number of financial services associations called for regulatory agencies to do "substantial additional work" on the Basel Committee on Banking Supervision's (“BCBS”) proposed framework, in advance of the U.S. consideration of the Fundamental Review of the Trading Book ("FRTB") rules. In a letter to the U.S. Department of the Treasury, the Office of the Comptroller of the Currency, the Federal Reserve Board of Governors and the FDIC, SIFMA et. al., warned of “potentially very negative impact[s] that the FRTB rules would have on the American financial markets, particularly as related to