OCC on Risk-Based Capital Guidelines

SIFMA, the American Bankers Association (ABA), The Clearing House (TCH), and the Financial Services Roundtable (FSR) provide comments to the Office of the Comptroller of the Currency (OCC) requesting an extension of the comment period for the proposal Risk-Based Capital Guidelines: Market Risk; Alternatives to Credit Ratings for Debt and Securitization Positions.  Given the complexity of the proposal, issues related to international consistency, and the press of responding to and implementing other legislative and regulatory proposals, the groups believe that the February 3, 2012 comment deadline for this proposal which calls for such a fundamental shift in capital regulation does not provide sufficient time to understand the full scope of the rule, and comment in a meaningful manner.