Advanced Notice of Proposed Rulemaking, Resolution-Related Resource Requirements for Large Banking Organizations

Published on:
January 23, 2023
Submitted to:
Federal Reserve and FDIC
Submitted by:
SIFMA

Summary

SIFMA provided comments to the Board of Governors of the Federal Reserve System (Federal Reserve) and Federal Deposit Insurance Corporation (FDIC) to solicit public input regarding whether an extra layer of loss-absorbing capacity could improve optionality in resolving certain large banking organizations (LBOs) or their insured depository institutions (IDIs), and the costs and benefits of such a requirement.

Excerpt

By Electronic Mail

January 23, 2023

Ann E. Misback, Secretary

Board of Governors of the Federal Reserve System

20th Street and Constitution Avenue, NW

Washington, DC 20551

James P. Sheesley, Assistant Executive Secretary

Attention: Comments RIN 3064–AF86

Federal Deposit Insurance Corporation

550 17th Street, NW

Washington, DC 20429

Re: Advanced Notice of Proposed Rulemaking, Resolution-Related Resource Requirements for Large Banking Organizations; Federal Reserve Docket No. R-1786, RIN 7100–AG44; FDIC RIN 3064-AF86

Dear Ms. Misback and Mr. Sheesley:

The Securities Industry and Financial Markets Association (“SIFMA”) appreciates the opportunity to comment on the advance notice of proposed rulemaking (“ANPR”) issued by the Board of Governors of the Federal Reserve System (the “Federal Reserve”) and Federal Deposit Insurance Corporation (the “FDIC” and, together with the Federal Reserve, the “Agencies”) to solicit public input regarding whether an extra layer of loss-absorbing capacity could improve optionality in resolving certain large banking organizations (“LBOs”) or their insured depository institutions (“IDIs”), and the costs and benefits of such a requirement.1

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1 See Federal Reserve and FDIC, Resolution-Related Resource Requirements for Large Banking Organizations, 87 Fed. Reg. 64,170 (Oct. 24, 2022).

SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).

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