The Clearing House (TCH) along with SIFMA, the ABA, the FSR and the IIB (Associations) filed a comment letter responding to the Fed’s NPR relating to restrictions on the terms of qualified financial contracts (QFCs) entered into by U.S. G-SIBs and the U.S. operations of foreign G-SIBs (together with U.S. G-SIBs, Covered Entities). The Associations strongly support the NPR, which they believe is a clear, well-considered effort to reduce systemic risk with minimal burden. However, the Associations believe that several minor modifications to the NPR will further the purpose of the NPR. The letter recommends: (i) modifications to exclude certain specialized entities from the definition of Covered Entity; (ii) modifications to exclude certain types of QFCs from the definition of Covered QFC to the extent not necessary to support rapid and orderly resolution or to avoid other adverse consequences; and (iii) clarifying changes to further the objectives of the NPR.
You Might Also Be Interested In...
Resolution & Recovery Planning New Large Bank Resolution Requirements Would Be Costly and Unnecessary
Resolution & Recovery Planning The Role of Credit Card Late Fees in Encouraging Timely Repayment Is Essential to Efficient Functioning of the Market
More Posts by This Author
Bank Liquidity Why Regulators Should Consider Banks’ Borrowing Capacity from the Fed in Liquidity Assessments
AML, Bank Secrecy Act and Sanctions BPI’s Heather Hogsett Testifies Before House Subcommittee on Cybersecurity, CISA’s Contributions