BPI submitted comments on the notice of proposed rulemaking to tailor the requirements in the Federal Reserve Board’s capital plan rule, which apply to bank holding companies and U.S. intermediate holding companies of foreign banking organizations with $100 billion or more in total consolidated assets. BPI generally supports and finds the proposed changes to be sensible; however, BPI offers numerous technical comments on ways in which they could be further improved. BPI also responds to the Fed’s request for comment on the capital planning guidance and further provided recommendations for changes to the capital planning rule.
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