Enhanced Prudential Standards & Early Remediation Regulations Under Dodd-Frank

Published on:
April 27, 2012

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.

See Also: Prior Submissions Reference in the Associations Comment Letter Regarding the Notice of Proposed Rulemaking Implementing Enhanced Prudential Standards and Early Remediation Regulations under Dodd-Frank 165/166

Details

Download

More Content

  • Letters
    Oct 22, 2026

    Treasury/IRS Notice 2026-49: Guidance on Section 324 of the SECURE 2.0 Act with Respect to Rollovers

    SIFMA supports modernizing retirement plan rollovers through standardized electronic processes, fraud safeguards and appropriate implementation timelines.
  • Amicus Briefs
    Oct 21, 2026

    In re USD LIBOR Litigation

  • Letters
    Oct 20, 2026

    SEC’s Proposed Rule Regulation Crypto Assets

    SIFMA and SIFMA AMG provide recommendations to the SEC on its proposed crypto asset regulation, addressing regulatory clarity, implementation and investor protection.

Get the latest trends, stats, and research on financial markets and securities.