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Comment Letters & Testimony - 2016

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 14, 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 

 

March 3
IIB submits comment letter to the New York State Department of Financial Services on its proposed rule on BSA/AML transaction monitoring/filtering and CCO attestation 

 

February 19
IIB submits comment letter on Federal Reserve Board’s proposed TLAC rules

 

February 16
IIB comment letter to the OCC on its proposed recovery planning guidelines.

 

February 1
The IIB submitted a comment letter to the Federal Reserve Board on its proposed revisions to Form FR Y-7

 

January 19
The IIB submitted a comment letter on the CFTC staff's preliminary report in November 2015 on the swap dealer de minimis exception. 

 

 

 

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