Enhanced Prudential Standards & Early Remediation Regulations Under Dodd-Frank
SIFMA, the American Bankers Association (ABA), the Financial Services Forum (FSF), The Clearing House (TCH), and The Financial Services Roundtable (FSR) provide comments to the Federal Reserve on enhanced prudential standards and early remediation regulations under sections 165 and 166 of the Dodd‐Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The groups warn against implementing regulations that are not properly designed and calibrated to the risks they are designed to address, they raise the potential for damage to the financial system and the broader economy. The groups greatest concern in this regard as to the Proposed Rules relates to the extraordinary overstatement of exposures in the single‐counterparty credit limits (the SCCL).
The groups focus their additional observations and recommendations in the specific areas of the proposal, including: Risk‐Based Capital Requirements and Leverage Limits, Liquidity Requirements, Single‐Counterparty Credit Limits, Risk Management , Supervisory Stress Test Requirements and Company‐Run Stress Test Requirements, and Early Remediation Framework.