The Clearing House (TCH), along with SIFMA, the ABA, the FSF, the FSR, and the IIB (Associations) filed a comment letter to the OCC on its NPR relating to restrictions on the terms of qualified financial contracts (QFCs) entered into by federally chartered and licensed financial institutions that are a part of U.S. banks identified as GSIBs or the U.S. operations of FBOs that are GSIBs. The NPR corresponds to recent proposed rules promulgated by the Federal Reserve and recent proposed rules promulgated by the FDIC. The Associations are supportive of the NPR, but recommend some minor modifications. Notably, the Associations believe that there are two modifications that should be made with respect to the OCC’s NPR in addition to those modifications proposed in the August 2016 comment letter, and they are: clarify that the implementation timeline for the NPR will be harmonized with the implementation timeline for both the Fed Rules and the FDIC Rules; clarify that subsidiaries of Covered Banks will be covered by the NPR and not by the Fed Rules; and clarify that the standards and processes set forth for approving alternative enhanced creditor protection conditions are consistent and harmonized as among the OCC, the Federal Reserve and the FDIC.
You Might Also Be Interested In...
AML, Bank Secrecy Act and Sanctions BPI Submits Comment Letter to FinCEN Regarding AML Program Effectiveness
Bank Governance BPI Offers Recommendations to NY Financial Services Regulator on a Re-Proposed Regulation on Disclosure of Confidential Supervisory Information
Cybersecurity BPI Files Comment Letter with U.K. Banking Authorities in Response to Operational Resilience Proposals
Regulatory Reporting and Accounting BPI Submits Comment Letter to Banking Agencies on Revisions to Call Report
Resolution & Recovery Planning Putting “Too Big to Fail” to Rest: Evidence from Market Behavior in the COVID-19 Pandemic
Consumer Affairs BPI Joins Joint Coalition Comment Letter Responding to CFPB NPR on General Qualified Mortgage Definition
More Posts by This Author
FinTech & Innovation FinTech and Big Tech Companies Want the Benefits of Banking Without the Responsibilities. Regulatory Loopholes Could Let Them Succeed.
COVID-19 Relief BPI and Joint Coalition Urge House and Senate Leadership to Address PPP Forgiveness Process
Bank Capital and Stress Testing The Farmer and the Seed Corn: Why Lowering the CCyB and Imposing Dividend Restrictions Are Opposites
AML, Bank Secrecy Act and Sanctions FinCEN Should Focus on Flexibility, Clarity and Coordination When Defining AML Effectiveness
COVID-19 Relief Loan Necessity Questionnaires -Borrower & Lender Coalition Letter to Congressional Leadership