The Global Financial Markets Association (GFMA), The Clearing House
Association (TCH), the American Bankers Association (ABA), The Financial
Services Roundtable (FSR), the Institute of International Bankers (IIB), and the
Institute of International Finance (IIF) collectively, welcome the opportunity
to comment on the Consultative Document on Effective Resolution of
Systemically Important Financial Institutions published by the Financial
Stability Board (FSB) on July 19, 2011 (Consultative Document).
The
groups strongly agree with the overall objective of the Consultative Document –
that authorities in all relevant jurisdictions should have the capacity to
resolve systemically important financial institutions (“SIFIs”) without systemic
disruption and without exposing the taxpayer to the risk of loss, within a
reasonable timeframe. Taxpayer-funded bailouts have been chosen in the past,
including during the recent global financial discrimination will be an
impediment to cross-border resolutions of G-SIFIs. Instead, foreign and domestic
deposits, and foreign and domestic depositors, should be treated as a single
class in any depositor preference law.
