IIB Supports Targeted Exemption to Ensure Treasury Clearing Market Liquidity    

NEW YORK, NY – In response to the Securities and Exchange Commission’s (SEC) request for comment regarding the ‘Notice of Request for Exemptive Relief,’ the Institute of International Bankers (IIB) has submitted a comment letter supporting a targeted exemption from certain Treasury clearing requirements for non-U.S. transactions.

The IIB’s response addresses concerns that transactions without a meaningful U.S. nexus could be subject to unnecessary clearing requirements, and that the exemptive relief proposed would preserve access to clearing and supporting the efficiency and resiliency of U.S. Treasury markets.

“Our members are strong participants in U.S. Treasury markets,” stated IIB’s CEO, Beth Zorc,“ but the extraterritorial application of these requirements could introduce legal, operational, and cost challenges that were not fully considered as required by the APA. A targeted exemption would help preserve their ability to participate efficiently in these markets while continuing to support liquidity and stability.”

Key Recommendations and Considerations:

·      Exemption for Non-U.S. Transactions: The IIB recommends exempting eligible secondary market transactions between non-U.S. participants and non-U.S. clients from the Trade Submission Requirement.

·      Holistic Framework: The letter supports a broader exemption framework that would also address certain transactions involving foreign affiliates and foreign branches, ensuring consistent treatment across market structures.

·      Supporting Market Liquidity and Resiliency: The IIB noted the exemption would remove barriers to non-U.S. participation and promote capital flows into U.S. Treasury markets, strengthening overall market liquidity and resiliency.

·      Avoiding Market Disruptions: The IIB cautioned that without relief, firms may restructure repo transactions or withdraw from direct participation in U.S. Treasury clearing, leading to higher costs, reduced participation, and less efficient access to clearing.

Click HERE to read the letter.

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The Institute of International Bankers (IIB) represents the U.S. operations of internationally headquartered financial institutions from more than 35 countries around the world. The membership consists of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States. The IIB works to ensure a level playing field for these institutions, which supported $5.4 trillion in foreign direct investment by underwriting more than 70% of debt issuance in the United States by internationally headquartered companies over the last four years. These institutions also underwrote more than 40% of U.S. financing raised since 2020 and comprise the majority of U.S. primary dealers.

IIB Applauds Release of Capital Proposals

NEW YORK, NY – The Institute of International Bankers (IIB) issued the following message in connection with the release of proposals to revise capital requirements.

“The IIB welcomes the release of the capital proposals and applauds the hard work by agency staff in advancing this effort. This is a critical step forward in finishing the work started over a decade ago.  We support an open and constructive dialogue during the rulemaking process and appreciate the agencies’ commitment to a thoughtful and transparent approach.  We look forward to sharing our views on these important rules.” 

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The Institute of International Bankers (IIB) represents the U.S. operations of internationally headquartered financial institutions from more than 35 countries around the world. The membership consists principally of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States. The IIB works to ensure a level playing field for these institutions, which are an important source of credit for U.S. borrowers and comprise the majority of U.S. primary dealers. These institutions enhance the depth and liquidity of U.S. financial markets and contribute significantly to the U.S. economy through direct employment of U.S. citizens, as well as through other operating and capital expenditures.   

Institute of International Bankers Announces Deutsche Bank’s Chief Risk Officer of the Americas Jonathan Hummel as Co-Vice Chair of the Board

NEW YORK, NY – The Institute of International Bankers (IIB) announced today that Deutsche Bank’s Chief Risk Officer of the Americas, Jonathan Hummel, will serve as Co-Vice Chair of the IIB’s Board of Directors.

Appointed during the IIB’s Annual General Meeting, held in conjunction with the IIB’s Annual Washington Conference, Hummel brings more than two decades of experience in global risk management and financial markets, including senior leadership roles at Deutsche Bank and Goldman Sachs.

Alongside his fellow Co-Vice Chair Tony Dunne, US Country Manager of the Bank of Ireland, Hummel will work with Board Chair Richard Haworth, CEO of Barclays Americas, and the IIB Board to guide the organization’s strategic priorities and engagement on key policy issues affecting internationally headquartered financial institutions operating in the United States.

“We are pleased to welcome Jonathan as Co-Vice Chair of the IIB Board,” said Richard Haworth, Chair of the IIB Board and CEO of Barclays Americas. “Jonathan brings deep industry expertise and a strong commitment to the mission of the IIB. His leadership and perspective will be invaluable as we continue to advocate for policies that support a strong and competitive international banking presence in the U.S. and the vital role our members play in driving economic growth across the United States.”

“Internationally headquartered banks make significant and meaningful contributions to the U.S. economy, and the IIB provides a valuable forum for engagement on shared issues,” said Hummel. “I’m honored to serve as Co‑Vice Chair and to work with Richard, the Board, and IIB leadership in support of the organization’s mission and its members.”  

Pictured (left to right): Jonathan Hummel, Chief Risk Officer of the Americas, Deutsche Bank; Beth Zorc, CEO, Institute of International Bankers; and Richard Haworth, CEO of Barclays Americas and Chair of the IIB Board

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The Institute of International Bankers (IIB) represents the U.S. operations of internationally headquartered financial institutions from more than 35 countries around the world. The membership consists of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States. The IIB works to ensure a level playing field for these institutions, which supported $5.4 trillion in foreign direct investment by underwriting more than 70% of debt issuance in the United States by internationally headquartered companies over the last four years. These institutions also underwrote more than 40% of U.S. financing raised since 2020 and comprise the majority of U.S. primary dealers.

IIB Recommends Enhancements to Federal Reserve Proposal on Supervisory Stress Test Transparency and Capital Planning Requirements

NEW YORK, NY – The Institute of International Bankers (IIB) today submitted a comment letter to the Board of Governors of the Federal Reserve System regarding its proposal to enhance transparency and public accountability in the supervisory stress testing framework. The proposal also includes modifications to capital planning requirements, the Stress Capital Buffer, and enhanced prudential standards.  In its letter, the IIB supports improvements to stress test transparency and outlines targeted recommendations that improve model calibration and risk sensitivity.

“We support the Federal Reserve’s efforts to enhance transparency in the stress testing process,” said Beth Zorc, CEO of the Institute of International Bankers. “We believe targeted refinements to model calibration and risk sensitivity will further strengthen the framework and ensure it appropriately reflects the business models of internationally headquartered financial institutions operating in the United States.”

Among the IIB’s recommendations are the following:

·      Incorporate transfer pricing arrangements in Pre-Provision Net Revenue (PPNR) and allow additional risk-mitigating hedges to have a beneficial effect on PPNR.  Current PPNR modeling will be overly punitive to internationally headquartered financial institutions, and the framework may understate non-interest revenue and overstate risk exposure in stress scenarios.  Incorporating transfer pricing arrangements and recognizing additional risk-mitigating hedges would improve the accuracy and risk sensitivity of the supervisory stress test without weaking prudential safeguards.

·      Allow Deferred Tax Assets (DTAs) from timing throughout the stress horizon by applying the capital rules’ deduction and risk-weighting of such DTAs.  Regardless of initial pre-press DTA composition, this approach would create uniformity and equality across firms.  Additionally, it reduces complexity and administrative burden by applying a process already used in capital planning and it increases transparency without compounding unknown projections.

·      Revise the threshold at which the global market shock (GMS) component of the annual stress test is applied to exclude firms that are Category III and below. The only firms other than Category I U.S. GSIBs that are currently subject to the GMS are two intermediate holding companies (IHC), neither of which are even in Category II. The IHCs are materially smaller than any U.S. GSIB, both in terms of total assets, as well as their trading assets and liabilities. Additionally, there are important differences in the riskiness and systemic importance of the trading asset portfolios of the IHCs, compared to the U.S. GSIBs.

Click HERE to read the letter.

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The Institute of International Bankers (IIB) represents the U.S. operations of internationally headquartered financial institutions from more than 35 countries around the world. The membership consists of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States. The IIB works to ensure a level playing field for these institutions, which supported $5.4 trillion in foreign direct investment by underwriting more than 70% of debt issuance in the United States by internationally headquartered companies over the last four years. These institutions also underwrote more than 40% of U.S. financing raised since 2020 and comprise the majority of U.S. primary dealers.

NEW YORK, NY – The Institute of International Bankers (IIB) recommended that the SEC exempt internationally headquartered financial institutions (IHFIs) from any amendments to the foreign private issuer (FPI) definition in a comment letter submitted Monday.

The letter states that IHFIs appreciate the importance of providing adequate information to U.S. investors to increase transparency, bolster public trust and confidence, and allow them to make well informed decisions. It also points out that IHFIs are highly regulated in the United States and are required to make comprehensive disclosures about their financial condition above and beyond what the typical public company must disclose.

Accordingly, “[i]f the SEC decides to make substantive changes to the FPI definition and accommodations as discussed in the Concept Release, the IIB urges the SEC to exempt IHFIs as a sub-set of the FPI population, from being subject to any such changes. We believe that this exemption is warranted because, as highly regulated financial institutions, IHFIs are already subject to extensive disclosure requirements,” the IIB letter states.

If the SEC does not authorize an exemption for IHFIs, the IIB urges the Commission to consider the following concerns:

·      The current definition is clear, practical, and reasonable and any change would have substantial negative consequences for IHFIs to the detriment of the market and the ability of U.S. investors to access geographically diverse investment opportunities.

·      The current FPI accommodations are reasonable and provide sufficient information to U.S. investors, including disclosures required by the flexible reporting accommodation

·      Requiring a foreign trading volume requirement would remove FPI eligibility from the issuer’s control and raise the cost of a firm’s compliance.

·      Instituting a major foreign exchange listing requirement will lead to regulatory uncertainty.

·      Requiring an assessment of foreign regulation is an administratively challenging and time-consuming exercise that may not be the best use of the Commission’s precious resources.

Click HERE to read the letter.

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The Institute of International Bankers (IIB) represents the U.S. operations of internationally headquartered financial institutions from more than 35 countries around the world. The membership consists of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States. The IIB works to ensure a level playing field for these institutions, which supported $5.4 trillion in foreign direct investment by underwriting more than 70% of debt issuance in the United States by internationally headquartered companies over the last four years. These institutions also underwrote more than 40% of U.S. financing raised since 2020 and comprise the majority of U.S. primary dealers.

FOR IMMEDIATE RELEASE

August 26, 2025

Media Contact

Jake Schmied

jschmied@iib.org

646-213-1146

IIB Recommends Tailoring of Enhanced Supplementary Leverage Ratio

NEW YORK, NY – The Institute of International Bankers (IIB) supports the aim of the banking agencies’ proposal to recalibrate regulatory capital requirements to reduce disincentives for large banking organizations to participate in the U.S. Treasury (UST) market.  In its comment letter submitted today, the IIB urged the banking agencies to go beyond adjustments to the enhanced Supplementary Leverage Ratio (eSLR) and to consider additional changes that could more broadly and effectively serve the same goals as the Proposal. 

“We recommend adjustments to the leverage capital, risk-based capital and stress testing frameworks applicable to the U.S. intermediate holding companies of international banks, as well as changes to the calculation of certain risk-based indicators under the Agencies’ tailoring framework—these changes would have a broader positive impact on the ability of all banking organizations, including international banks, to continue these essential activities,” the IIB letter notes.

Among the IIB’s recommendations are that the Agencies should:

·      Make targeted adjustments to risk-based indicators with respect to USTs.

·      Not apply the SLR to Category III (BHCs) and (IHCs) with under $250 billion in total assets

·      Recalibrate the Tier 1 leverage ratio to 3% for BHCs and IHCs in Category III and below.

·      Revise the stress capital buffer requirements to better calibrate the risk profile tests

·      Recalibrate downward the internal total loss-absorbing capacity requirements

Click HERE to read the letter.

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The Institute of International Bankers (IIB) represents the U.S. operations of internationally headquartered financial institutions from more than 35 countries around the world. The membership consists of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States. The IIB works to ensure a level playing field for these institutions, which supported $5.4 trillion in foreign direct investment by underwriting more than 70% of debt issuance in the United States by internationally headquartered companies over the last four years. These institutions also underwrote more than 40% of U.S. financing raised since 2020 and comprise the majority of U.S. primary dealers.

FOR IMMEDIATE RELEASE

June 23, 2025

Media Contact

Garrett Hawkins

ghawkins@iib.org

810-623-2932

NEW YORK, NY – The Institute of International Bankers (IIB) recommended improvements to more appropriately calibrate the Federal Reserve Board’s (FRB) annual stress test framework for the U.S. operations of international banks in a comment letter submitted today. While supportive of the FRB’s proposal to average stress test results, the IIB believes it’s also important to modify the framework to better reflect the risk of certain assets or activities and the overall risk profiles of stress test participants.

“We believe it is imperative that any underlying issues of uncertainty, lack of transparency and planning disruption arising from the stress testing framework are not just ameliorated by averaging, but that the individual elements of the stress tests are appropriately calibrated,” the IIB letter notes.

Among the IIB’s recommendations are the following key improvements:

^·              Revise the threshold at which the global market shock (GMS) component of the annual stress test is applied to exclude firms that are Category III and below. The only firms other than Category I U.S. GSIBs that are currently subject to the GMS are two intermediate holding companies (IHC), neither of which are even in Category II. The IHCs are materially smaller than any U.S. GSIB, both in terms of total assets, as well as their trading assets and liabilities. Additionally, there are important differences in the riskiness and systemic importance of the trading asset portfolios of the IHCs, compared to the U.S. GSIBs.

·      Eliminate the dividend add-on component of the stress capital buffer (SCB) for IHCs. The dividend add-on is biased against IHCs, given their materially different profile as subsidiaries of a larger organization. IHCs effectively do not, and often cannot, distribute capital through share repurchases. As a result, the exclusion for share repurchases, rather than dividends on shares, is a benefit in the stress capital buffer framework that becomes unusable and irrelevant to IHCs. 

·      Tailor the operational risk elements of the overall capital framework for IHCs. The IIB urges the U.S. banking agencies to continue excluding IHCs (as Category III or IV institutions) from the operational risk elements of risk-weighted asset determinations in any future Basel III Endgame proposal. Many, if not all, IHCs are already subject to the Basel III Endgame’s operational risk capital requirements on a consolidated basis through their parent. The operational risk capital required by the stress tests sufficiently allocates global capital to the United States for operational risk.

If, however, operational risk is included in both the stress test and a revised Basel III Endgame proposal, recalibration and a holistic approach are essential. In addition to general recalibration downward to account for the overlap, these elements in the stress test should be substantially amended to avoid compounding operational risk stresses across the stress test and any elements of the risk-weighted asset rules.

Click HERE to read the letter.

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The Institute of International Bankers (IIB) represents the U.S. operations of internationally headquartered financial institutions from more than 35 countries around the world. The membership consists of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States. The IIB works to ensure a level playing field for these institutions, which supported $5.4 trillion in foreign direct investment by underwriting more than 70% of debt issuance in the United States by internationally headquartered companies over the last four years. These institutions also underwrote more than 40% of U.S. financing raised since 2020 and comprise the majority of U.S. primary dealers.

Washington, D.C. — A coalition of financial trade associations today urged the Cybersecurity and Infrastructure Security Agency to rescind and reissue its proposed cyber incident reporting rule to implement the Cyber Incident Reporting for Critical Infrastructure Act. The groups — including the Bank Policy Institute, American Bankers Association, Institute of International Bankers and the Securities Industry and Financial Markets Association — warn that the proposed rule diverges from congressional intent, imposes unnecessary burdens and shifts critical cybersecurity resources away from defending institutions and their customers.

“We believe the proposed rule will have significant and detrimental repercussions if not substantially revised,” the Associations wrote. “As such, we ask that you work with industry to craft a new rule that allows a victim company to focus its resources on responding to an attack rather than filing government reports.”

What They’re Saying:

CIRCIA, signed into law in March 2022, was championed by bipartisan lawmakers to strengthen cyber incident reporting without creating undue burdens. However, key congressional leaders now express concern that CISA’s proposed rule exceeds its mandate:

• “The NPRM ignores the burden to industry by asserting that technology will process the amount of information it requests . . . [The proposal would] undoubtedly skyrocket[] compliance work and clashes with congressional intent.” - Rep. Andrew Garbarino (R-NY)
• “The NPRM appears to, at times, mischaracterize or dismiss Congressional intent” - Reps. Bennie Thompson (D-MS), Yvette Clarke (D-NY), and Eric Swalwell (D-CA)
• "[I]t is very important that the regulation is well-crafted and reflects both Congressional intent and the public’s recommendations.  As currently written, I have concerns that the effect of this proposed rule fails to hit this mark.”  - Sen. Gary Peters (D-MI)

What are the associations requesting?

As the Associations have previously advocated, the successful implementation of this rule must account for the following:

• Limit the scope of reporting to what matters most. The current scope is too broad and risks overwhelming regulators with irrelevant data. Instead, limit reporting to substantial incidents that affect critical services. Moreover, CISA should clarify that the reporting requirements only apply to the U.S. operations of financial institutions and would not apply if an incident occurs entirely outside of the United States.
• Focus data collection on what companies “need to know” to prevent contagion. The information collected should be based on actionable information that could be shared with other companies to protect the economy and prevent the exploitation of similar vulnerabilities.
• Clarify and reduce the supplemental reporting requirements applicable to covered entities. Regular status updates are important, however, requiring constant reports is not useful and ties up critical response resources.
• Reduce the amount of time firms are required to keep forensic data. CISA should shorten the time that financial institutions are required to save data so they aren’t forced to incur expenses for data that may no longer be necessary.

To access a copy of the letter, please click here.

 
IIB Advocates for Critical Changes to FinCEN’s AML Program Proposal

NEW YORK, NY – The Institute of International Bankers (IIB) advocated for critical changes to a proposed rule implementing the Anti-Money Laundering (AML) Act of 2020 in a comment letter to the Financial Crimes Enforcement Network (FinCEN) yesterday. The proposed rule would require the U.S. operations of international banks to onshore significant portions of their anti-money laundering and countering the financing of terrorism (AML/CFT) programs that are currently conducted offshore, a change which is extraordinarily burdensome, impracticable to implement in the short- and medium-term, and potentially infeasible.

“The IIB strongly urges FinCEN, in implementing the statutory language of the AML Act, to recognize that requiring significant onshoring of AML/CFT processes would run counter to the AML Act’s and the Proposed Rule’s shared aim of ensuring financial institutions manage risks effectively across their enterprises,” the letter reads.

“Current holistic risk management practices for multinational financial institutions necessarily incorporates non-U.S. processes and personnel,” the letter continues. “The IIB urges FinCEN not to upend current effective AML/CFT practices and to afford financial institutions flexibility to conduct processes in ways they determine are most effective.”

Rather than mandating that AML/CFT duties areconducted by individuals in the United States, the IIB advocates that the rule instead requireoversight of U.S. AML/CFT functions by individuals in the U.S., which is consistent with AML Act language.

Among other issues, the IIB recommends:

• Considering the stated goal of promoting flexibility in AML/CFT programs, FinCEN should avoid imposing a rule that lessens financial institutions’ flexibility through one-size-fits-all requirements and clarify that the proposed rule is intended to allow financial institutions flexibility to determine on a risk basis what constitutes an effective, risk-based and reasonably designed AML/CFT program.
  
  
• Given the significance of the proposed changes, the IIB suggests that FinCEN consider hosting “roundtable” meetings with financial institutions and other stakeholders to obtain feedback on existing processes and potential impacts of the proposed rule and to foster alignment on the proposed amendments before they are finalized.

• An effective date of at least two years from the date of issuance of the final rule is necessary to comply with the proposed changes andthe IIBurges FinCEN to ensure expectations for how banks will be examined for compliance are published well in advance of the effective date, so that banks can take such guidance into account in their implementation efforts.

Click HERE to read the letter.

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The Institute of International Bankers (IIB) represents the U.S. operations of internationally headquartered financial institutions from more than 35 countries around the world. The membership consists principally of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States. The IIB works to ensure a level playing field for these institutions, which are an important source of credit for U.S. borrowers and comprise the majority of U.S. primary dealers. These institutions enhance the depth and liquidity of U.S. financial markets and contribute significantly to the U.S. economy through direct employment of U.S. citizens, as well as through other operating and capital expenditures.  

BPI Media Contact: Austin Anton, austin.anton@bpi.com

IIB Media Contact: Garrett Hawkins, ghawkins@iib.org

SIFMA Media Contact: Katrina Cavalli, kcavalli@sifma.org 

CISA Misses Mark on Proposed Cyber Incident Reporting Rule

ABA, BPI, IIB and SIFMA comment on shortfalls of CIRCIA proposal

Washington, D.C. —The American Bankers Association, Bank Policy Institute, Institute of International Bankers and the Securities Industry and Financial Markets Association raised serious concerns today in a letter to the Cybersecurity & Infrastructure Security Agency on its plan to implement new cyber incident reporting laws. The proposed rule would require victims of cyber incidents, like a data breach or other attack, to report to CISA within 72 hours of determining that an incident has occurred.

“Congress directed CISA to create a rule that gives regulators timely intelligence without diverting front-line defenders from the immediate task of stopping the attack,” the Associations commented upon filing the letter. “CISA has thus far failed to strike that balance, disregarded congressional intent and risks straining the U.S. financial system’s cyber defenses. Significant changes must be made for this proposal to be useful to regulators and industry; otherwise, CISA is moving forward with another requirement that prioritizes routine government reporting over the security needs of firms.”

The proposal is in response to the Cyber Incident Reporting for Critical Infrastructure Act, which financial institutions supported when it became law in March 2022. CISA engaged in a series of listening sessions following CIRCIA’s passage, and the Department of Homeland Security also issued its own set of recommendations identifying 45 different reporting requirements across the federal government, each with disparate standards and thresholds, that warrant greater harmonization. However, the proposal does not adequately address these shortcomings.

Our recommendations:

CISA should make the following changes to better align with the CIRCIA statute and achieve a more coordinated and effective cyber incident response:

• Limit the scope of reporting to what matters most. The current scope is too broad and risks overwhelming regulators with irrelevant data. Instead, limit reporting to substantial incidents that affect critical services. Moreover, CISA should clarify that the reporting requirements only apply to the U.S. operations of financial institutions and would not apply if an incident occurs entirely outside of the United States.
• Focus data collection on what companies “need to know” to prevent contagion.The information collected should be based on actionable information that could be shared with other companies to protect the economy and prevent the exploitation of similar vulnerabilities.
• Clarify and reduce the supplemental reporting requirements applicable to covered entities.Regular status updates are important, however, requiring constant reports is not useful and ties up critical response resources.
• Reduce the amount of time firms are required to keep forensic data.CISA should shorten the time that financial institutions are required to save data so they aren’t forced to incur expenses for data that may no longer be necessary.

Click here to view the letter.

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About the American Bankers Association

The American Bankers Association is the voice of the nation’s $24 trillion banking industry, which is composed of small, regional and large banks that together employ approximately 2.1 million people, safeguard $19 trillion in deposits and extend $12.4 trillion in loans.

About Bank Policy Institute

The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.

About IIB

The Institute of International Bankers (IIB) represents the U.S. operations of internationally headquartered financial institutions from more than 35 countries around the world. The membership consists principally of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States. The IIB works to ensure a level playing field for these institutions, which are an important source of credit for U.S. borrowers and comprise the majority of U.S. primary dealers. These institutions enhance the depth and liquidity of U.S. financial markets and contribute significantly to the U.S. economy through direct employment of U.S. citizens, as well as through other operating and capital expenditures.

About SIFMA
SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development.  SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).