SIFMA submitted the attached comments to the Federal Reserve Board, the FDIC, and the OCC on the proposed CVA capital requirements, including the simple CVA approach and the advanced CVA approach under Regulatory Capital Rules: Standardized Approach for Risk-Weighted Assets; Market Discipline and Disclosure Requirements. View comment letter here (links externally to SIFMA website).

SIFMA submitted the attached comments to the Federal Reserve Board, the FDIC, and the OCC on the proposed treatment of unrealized gains and losses on U.S. municipal debt securities under Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Minimum Regulatory Capital Ratios, Capital Adequacy, Transition Provisions, and Prompt Corrective Action. View comment letter here (links externally to SIFMA website).

The Treasury Committee has published its report on the failure of the FSA's oversight of RBS. The report describes the relevant events as being a "serious indictment" of the regulator. In addition to this critique of the FSA, the Treasury Committee has commented in its report that: New Prudential Regulation Authority should be empowered to approve major bank mergers and acquisitions; and Legislation currently being considered on banking reform deserves greater scrutiny. Lofchie Comment: Many of the issues raised in the report have parallels in U.S. regulation. I also note that, in yesterday's

SIFMA, American Bankers Association (ABA) and Financial Services Roundtable (FSR) (collectively, the "Associations") submitted a letter on three notices of proposed rulemaking issued by the OCC, the Federal Reserve Board and the FDIC ("Agencies") which would comprehensively revise the regulatory capital framework for all U.S. banking organizations. The proposals include: (i) Basel III Numerator NPR; (ii) Standardized Approach NPR; and (iii) Advanced Approaches NPR (collectively, the "proposals"). In the letter, the Associations asserted that the Agencies have employed an overly conservative

Reprinting a report by the Charlotte Observer, the House Financial Services Committee blog stated that community banks are finding ways to "trim regulatory costs and save money" with the help of certain provisions of the JOBS Act. According to the reprinted newspaper article, almost 100 U.S. banks were in the process of deregistering with the SEC in light of the higher number of investors that is now required to trigger a registration requirement. View blog post and related report here (links externally to House Financial Services Committee website).