Risk-Based Capital Guidelines

SIFMA, The Clearing House (TCH), the American Bankers Association (ABA), the Financial Services Roundtable (FSR), the International Swaps and Derivatives Association, Inc. (ISDA), and the American Securitization Forum (ASF) provide comments to the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) on the incorporation alternative methodologies for calculating specific risk capital requirements for debt and securitization positions that do not rely on credit ratings into the joint agencies’ proposed market risk capital rules, Federal Reserve Docket No. R-1401, RIN 7100-AD61, Docket ID OCC-2010-0003, RIN 1557-AC99, FDIC RIN 3064-AD70.  The groups share their overarching concerns with the proposed rule. In addition, the letter details their concerns with respect to the proposed rule’s methodologies applicable to exposures other than securitizations and to securitizations, respectively.