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February 13, 2023

In a comment letter on the FRB's "Principles for Climate-Related Financial Risk Management for Large Financial Institutions," the American Bankers Association supported efforts to create "a high-level guide for the largest institutions," but raised concerns on both substance and process.

January 25, 2023
Commentary by Steven Lofchie

In response to an Advance Noticed of Proposed Rulemaking that would add "an extra layer of loss-absorbing capacity" in resolving certain large banking organizations, SIFMA said that it is both unnecessary and inappropriate to extend the enhanced resolution requirements to non global systemically important banking organizations whose primary operations are as retail broker-dealers.