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

Date

20

October

2017