On October 31, BPI, IIB, SIFMA, and ABA submitted an unsolicited supplemental comment letter to the Fed, OCC, and FDIC addressing significant issues raised by the final tailoring rules. The letter urges that U.S. IHCs be permitted to calculate their initial cross-jurisdictional activity indicator using the FR Y-15 filing as of June 30, 2020, with certain changes to the FR Y-15 reporting form, to avoid the inappropriate categorization of certain U.S. IHCs as Category II based on a measure of cross-jurisdictional activity on the current FR Y-15 form which is inconsistent with the risk-based indicator in the final rules. The letter also requests that the agencies promptly after publication of the final rule in the Federal Register align the weighted short-term wholesale funding indicator with the other risk-based indicators, clarify the effective dates that will apply under the final rules and provide additional guidance on capital planning and CCAR for Category III and Category IV firms.
BPI, IIB, SIFMA, and ABA Submit Supplemental Comment Letter to Agencies on Final Tailoring Rules
