On June 7, the Bank Policy Institute, Financial Services Forum and the Securities Industry and Financial Markets filed a comment letter responding to the U.S. banking agencies’ TLAC holdings regulatory capital proposal.
The letter offers several recommendations that would allow the final rule to address interconnectedness and other risks relating to a GSIB’s failure more appropriately. Our recommendations would further the policy objectives of efficiency and simplicity in regulation, and would also facilitate the ability of advanced approaches firms to engage in market-making activity, which supports the depth and liquidity of markets for TLAC-eligible debt.
