The Securities Industry and Financial Markets Association ("SIFMA"), the American Bankers Association ("ABA"), the Financial Services Forum ("FSF"), the Financial Services Roundtable ("FSR") and the Institute of International Bankers ("IIB") (collectively referred to as the "Associations") submitted a comment letter to the Board of Governors of the Federal Reserve System ("FRB") on complementary activities, merchant banking activities and other activities of financial holding companies ("FHCs") related to physical commodities. In the letter, the Associations stated that the public benefits of
A broad coalition of industry groups urged regulators to exclude client collateral when calculating the total assets of banks, and argued that an unchanged leverage ratio would "reduce access to clearing and undermine one of the main goals of financial reform." The industry groups made these points in a written response to FDIC Vice President Thomas Hoenig's article, "Weakening Leverage Ratio Undermines Banks' Accounting." The industry groups asserted that Mr. Hoenig's commentary on the Basel Committee's leverage ratio contained "some flaws in its application to cleared derivatives," and
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
SIFMA provided notice to banking regulators (the Board of Governors of the Federal Reserve, the Office of the Comptroller of the Currency and the FDIC) of a forthcoming change in the treatment of variation margin payments for over-the-counter derivatives by central clearing counterparties ("CCPs"). Historically, variation margin payments have been treated as collateral for outstanding exposure, a treatment that a SIFMA comment letter refers to as the "collateralized to market" ("CTM") model. Going forward, the CCPs will adopt a model by which variation margin payments are treated as settlement
Several financial services associations submitted comments to the Board of Governors of the Federal Reserve System in response to a proposal to impose total loss-absorbing capacity, long-term debt and related "clean holding company" requirements on global systemically important banking groups.