January 31, 2020

Via Electronic Mail

Chief Counsel’s Office
Office of the Comptroller of the Currency
400 7th Street, SW, Suite 3E-218
Washington, D.C. 20219

Ann E. Misback, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, D.C. 20551

Robert E. Feldman, Executive Secretary
Attention: Comments/Legal ESS
Federal Deposit Insurance Corporation
550 17th Street, NW
Washington D.C. 20429

Re: Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of Global Systemically Important U.S. Bank Holding Companies, Certain Intermediate Holding Companies, and Global Systemically Important Foreign Banking Organizations (Docket ID OCC–2018–0019 and RIN1557–AE38; FRB Docket No. R–1655 and RIN 7100 AF43; FDIC RIN 3064–AE79)

Ladies and Gentlemen:

The Bank Policy Institute, the Financial Services Forum and the Securities Industry and Financial Markets Association (the “Associations”)1 welcome the opportunity to supplement our comment letter dated June 7, 2019 (the “June Comment Letter”) and submission dated October 9, 2019 (the “October Submission”) on the agencies’ proposal2 addressing the regulatory capital treatment of advanced approaches firms’ investments in certain unsecured debt instruments of U.S. GSIBs, foreign GSIBs and the U.S. IHCs of foreign GSIBs, including debt that qualifies as total loss-absorbing capacity but does not qualify as regulatory capital (“TLAC-eligible debt”).

The Associations appreciate the agencies’ consideration of the June Comment Letter and the October Submission as well as the opportunity to discuss the June Comment Letter and the October Submission with the agencies in September and December 2019. In this letter, we respond to a number of the questions the agencies asked in December 2019.

1 See Annex A for a description of each of the Associations.
2 84 Fed. Reg. 13814 (Apr. 8, 2019).