The Bank Policy Institute[1] and the Institute of International Bankers[2] appreciate the opportunity to comment on the proposal by the Board of Governors of the Federal Reserve System to revise the Report of Selected Money Market Rates (FR 2420).[3]The Associations understand the Federal Reserve’s desire to “improve monitoring of the transition away from the London Interbank Offered Rate (LIBOR), strengthen the reference rate production process, and ensure the integrity of reported data,”[4]and are generally supportive of the proposed new data item to specify the day-count convention used for all interest rates reported on FR 2420, as well as the addition of reference rate options for floating-rate time deposits and CDs. However, there are significant concerns with respect to the proposed changes to the submission dates of the FR 2420, particularly regarding the proposed submission deadline of Parts A, B, and D. In addition, our letter includes a request for clarification with respect to the added reference rate options and the new day-count convention data item, as well as recommends the release of the modified draft reporting instructions for comment, prior to implementation of the clarifying additions to the instructions noted in the proposal.
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[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.
[2] The Institute of International Bankers is the only national association devoted exclusively to representing and advancing the interests of the international banking community in the United States. Its membership is comprised of internationally headquartered banking and financial institutions from over 35 countries around the world doing business in the United States. The IIB’s mission is to help resolve the many special legislative, regulatory, tax, and compliance issues confronting internationally headquartered institutions that engage in banking, securities and other financial activities in the United States. Through its advocacy efforts the IIB seeks results that are consistent with the U.S. policy of national treatment and appropriately limit the extraterritorial application of U.S. laws to the global operations of its member institutions.
[3] 86 Fed. Reg. 23971 (May 5, 2021).
[4] Id at 23972.
