Financial Research Fund Assessment Fees

SIFMA, the American Bankers Association (ABA), The Clearing House (TCH), The Financial Services Roundtable (FSR), and the Institute of International Bankers provide comments to the U.S. Department of Treasury on the assessment of fees on large bank holding companies and nonbank financial companies supervised by the Federal Reserve Board to cover the expenses of the Financial Research Fund as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act), Docket No. TREAS-DO-2012-0001.  The Associations’ primary concern is that the Office of Financial Research (OFR) assessments should be transparent, equitable, reasonable, and predictable. The groups are unable to assess the proposed framework against these objectives because of the scant information provided in the proposal or otherwise available.