Letters

G-SIB Surcharge Calculation

Summary

SIFMA AMG provides comments to the Federal Reserve System regarding Proposed Changes to G-SIB Surcharge Calculation. The Proposal would penalize the clearing of client positions through a GSIB’s futures commission merchant by disproportionately increasing the G-SIB Surcharge scores for this activity. The Associations urge the Board to withdraw the Proposal due to its inconsistency with regulatory directives to clear derivatives – directives that the Associations have supported as beneficial to market stability and management of counterparty risks – and the negative and unwarranted effects the Proposal would have on clients that use cleared derivatives.

PDF

Submitted To

Federal Reserve System

Submitted By

SIFMA AMG

Committee

Asset Management Group (AMG)

Date

20

October

2017