Notice of Proposed Rulemaking Issued by the Federal Reserve

SIFMA, the American Bankers Association (ABA), The Clearing House (TCH), and The Financial Services Roundtable provide comments to the Board of Governors of the Federal Reserve (Federal Reserve) on the notice of proposed rulemaking (NPR) issued by the Federal Reserve that would require U.S. bank holding companies with $50 billion or more in total consolidated assets and certain other institutions to submit capital plans on an annual basis and to provide prior notice under certain circumstances before making capital distributions.  The groups have concerns with several aspects of the NPR, some of which go to substance and some of which go to the need for clarification.