On September 28, BPI filed a comment letter with the Financial Stability Board (FSB) in response to its Evaluation of the Effects of Too-Big-to-Fail (TBTF) reforms. The letter commends the FSB for its work and analysis and concurs with the report’s conclusion concerning ongoing monitoring of TLAC requirements, but calls for improved data analysis and an adjustment to the overall tone of the report to recognize the extraordinary progress being made to end TBTF in key G-SIB home jurisdictions since the 2008-crisis.
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