Comment Letters / Testimony | Publications
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Recent comment letters / testimony
December 19, 2016
Joint IIB-SIFMA comment letter on the CFTC cross-border proposal.
November 24, 2016
IIB comment letter on the Fed’s CCAR proposal
November 5, 2016
IIB comment letter on the NYS Department of Financial Services’ proposed cybersecurity regulations.
October 18, 2016
IIB comment letter on the OCC's proposed restrictions on qualified financial contracts (QFCs) of systemically important U.S. banking organizations and the U.S. operations of systemically important foreign banking organizations.
August 5, 2016
IIB comment letter on the Federal Reserve Board's proposed restrictions on Qualified Financial Contracts (QFCs) of systemically important U.S. banking organizations and the U.S.operations of systemically important foreign banking organizations
August 5, 2016
IIB comment letter on the proposed interagency rulemaking on the net stable funding ratio.
July 22, 2016
IIB comment letter on the proposed rules to implement the provisions of Section 956 of the Dodd-Frank Act with respect to covered financial institutions' incentive-based compensation arrangements.
July 1, 2016
IIB supplemental comment letter on the Federal Reserve's proposed rule prescribing total loss absorbing capacity (TLAC), long-term debt (LTD) and other requirements for systemically important U.S. bank holding companies and intermediate holding company (IHC) subsidiaries of systemically important FBOs
June 30, 2016
IIB comment letter on the Treasury Department's proposed regulations implementing the provisions of Section 385 of the Internal Revenue Code regarding treatment of certain interests in corporations as debt or equity for federal income tax purposes.
June 3, 2016
The IIB submitted a comment letter on the Federal Reserve Board's reproposed single counterparty credit limit rule under Section 165(e) of the Dodd-Frank Act.
June 3, 2016
The IIB filed comments on the Federal Reserve Board's proposed revisions to Form FR Y-7Q, the capital and assets report for FBOs
IIB comment letter to the OCC on its proposed recovery planning guidelines.
The IIB submitted a comment letter to the Federal Reserve Board on its proposed revisions to Form FR Y-7
The IIB submitted a comment letter on the CFTC staff's preliminary report in November 2015 on the swap dealer de minimis exception.
The IIB and several other financial industry trade associations submitted a joint comment letter in response to updated guidance (FAQs) published by the FDIC on November 13th regarding brokered deposits
The IIB joined with The Clearing House, the ABA and SIFMA in a joint comment letter on the Federal Reserve's proposed revisions to the FR Y-14 Forms
The IIB filed a comment letter on the Federal Reserve's proposed revisions to its "Banking Organization Systemic Risk Report" (Form FR Y-15)
The IIB joined a group of other industry trade associations in a comment letter on the SEC's "clawback" proposal under Section 954 of Dodd-Frank
Joint comment letter with SIFMA on the CFTC's proposed rules on the cross-border application of OTC margin requirements for uncleared swaps for swap dealers and major swap participants that do not have a prudential regulator.