GFMA submitted a response letter to the FSB in regarding its consultation on evaluation of too-big-to-fail (TBTF) reforms for banks. The response outlined key achievements in addressing TBTF, the areas that warrant further analysis and the other questions that should be asked in order to complete the evaluation.

GFMA, Bank Policy Institute (BPI), and the Institute of International Finance (IIF) provide this joint trades letter in response to the request of the Financial Stability Board (FSB) to submit views on the technical implementation of the FSB’s standard on the adequacy of total loss-absorbing and recapitalization capacity for Global Systemically Important Banks (G-SIBs) in resolution the Total Loss-Absorbing Capacity (TLAC) standard.

GFMA and IIF provide comments responding to FSB’s Thematic Peer Review on Bank Resolution Planning.

GFMA, the Clearing House, and IIF provide comments responding to FSB’s consultation on resolution funding strategies.  

GFMA and the Australian Securitisation Forum (AuSF) provide comments to the SEC regarding proposed revisions to Regulation AB under the U.S. Securities Act of 1933 (Regulation AB).

The Securities and Exchange Commission is re-opening the comment period for the Asset-Backed Securities Releases (Release Nos. 33-9552; 33-9244; File No. S7-08-10).

GFMA with the Institute of International Finance (IIF) provides comments to the Financial Stability Board (FSB) in response to the FSB consultative document on cross-border recognition of resolution action and on guidance on cooperation and information sharing with host authorities of jurisdictions not represented on CMGs where a G-SIFI has a systemic presence.

GFMA and the Institute of International Finance (IIF) provide comments to the Financial Stability Board (FSB) on the FSB's publication of a term sheet (TS) for Total Loss Absorbing Capacity (TLAC) for Global Systemically Important Banks (G-SIBs).

GFMA, the Institute of International Finance (IIF) the International Swaps and Derivatives Association, Inc (ISDA) provide comments to the Basel Committee on Banking Supervision (BCBS) on the revised Standardized Approach for Market Risk.

The industry believes that the Sensitivity Based Approach (SBA), as put forward by the BCBS, constitutes a significant improvement to the previous version of the methodology and is in line with industry recommendations on leveraging upon existing validated risk metrics to calculate the market risk capital requirements.

The Advanced Cash Flow Approach (ACFA) methodology, on the other hand, is not computationally supported by existing infrastructure, since cash flow data are not captured at the trade level. As a result, industry members would require extensive resources to adhere to currently proposed regulatory timelines whilst achieving little in terms of enhancing the risk sensitivity of output metrics. This would be particularly onerous for smaller organizations.

GFMA Chief Executive Simon Lewis writes to the editors of the Financial Times calling for G20 finance ministers and financial heads of all nations to formally endorse the robust application of the international principle of comity – where the home regulator defers to the host regulator where the latter’s rules are consistent with the G20 recommendations and best practices.

GFMA provides comments to the International Organization of Securities Commissions (IOSCO) offering recommendations on foundational principles for global coordination in cross-border regulation. IOSCO is creating a task force aimed at addressing cross-border regulatory coordination issues (the Task Force).

GFMA is supportive of the Task Force’s stated intention of issuing a public consultation paper focused on cross-border reform efforts and hosting public industry meetings for continued dialogue; and believes IOSCO can and should play an integral role in promoting coordination. Consequently, in advance of the Task Force’s consultation paper, GFMA writes to highlight several issues currently impacting cross-border regulatory coordination, which it believes are immediately actionable by IOSCO.

GFMA, SIFMA, The Clearing House Association L.L.C. (The Clearing House), the American Bankers Association, the Financial Services Roundtable and the Global Financial Markets Association provided comments to the Federal Deposit Insurance Corporation on their notice entitled Resolution of Systemically Important Financial Institutions: The Single Point of Entry Strategy.

The Notice describes the FDIC’s single-point-of-entry (SPOE) recapitalization within resolution strategy for resolving global systemically important banking groups (G-SIBs) with top-tier U.S. parent companies under Title II of the Dodd-Frank Wall Street Reform and Consumer Protection Act and requests comments on certain details and issues regarding how the FDIC would expect to carry out the SPOE Strategy with respect to U.S. G-SIBs.

See also:

78 FR 76614 - RESOLUTION OF SYSTEMICALLY IMPORTANT FINANCIAL INSTITUTIONS: THE SINGLE POINT OF ENTRY STRATEGY

GFMA provides comments to the Financial Stability Board (FSB) responding to the FSB Consultation Document: Application of the Key Attributes of Effective Resolution Regimes to Non-Bank Financial Institutions (Discussion Paper).  

GFMA summarises the key concerns and comments raised by GFMA members with respect to Appendix III of the Discussion Paper entitled “Client asset protection in resolution.”  Specifically, GFMA's comments focus on the definition of client assets and on client asset segregation rather than on resolution tools outlined in the Discussion Paper.

GFMA, the International Institute of Finance (IIF), the International Swaps and Derivatives Association, Inc. (ISDA), and The Clearing House (TCH) provide comments to the Financial Stability Board (FSB),  the Committee on Payment and Settlement Systems (CPSS) of the Bank for International Settlements (BIS), and the International Organization for Securities Commissioners (IOSCO) on the FSB Consultation Document: Application of the Key Attributes of Effective Resolution Regimes to Non-Bank Financial Institutions and the CPSS-IOSCO Consultative Report: Recovery of Financial Market Infrastructures (FMIs). 

Effective recovery, continuity and resolution mechanisms for FMIs are critical to the efficient operation and sustainability of the financial markets. It would be difficult, if not impossible, to maintain financial stability if essential services provided by FMI entities were to cease.

GFMA provides comments to the Financial Stability Board (FSB) in response to the FSB's Consultative Document:Information sharing for resolution purposes, 12 August 2013.

GFMA is strongly supportive of the work of the FSB towards establishing an effective cross-border recovery and resolution framework and the Key Attributes of Effective Resolution Regimes for Financial Institutions. Cross-border cooperation is a crucial requirement for effective cross-border resolution and GFMA strongly supports efforts to strengthen and facilitate greater cross-border cooperation in this area.  In that context, GFMA shares its expertise in response to the Consultative Document.

GFMA provides comments to the Financial Stability Board (FSB) on the Consultative Document, Recovery and Resolution Planning: Making the Key Attributes Requirements Operational.
GFMA strongly agrees with the objective of the Consultative Document, and appeciates the FSB’s efforts to monitor and assess how well the Key Attributes are being complied with across jurisdictions.  In addition, GFMA believes that progress on orderly resolution regimes should reduce the amount of any applicable G-SIFI surcharge. If a G-SIFI is resolvable, then the need for a surcharge premised on the lack of resolvability is substantially decreased and therefore any surcharge should be commensurably reduced.

GFMA provides comments to the Committee on Payment and Settlement Systems (CPSS) and the Technical Committee of the International Organization of Securities Commissions (IOSCO) in response to the Recovery and Resolution Consultative Report.

GFMA provides comments to the Commodity Futures Trading Commission (CFTC) on the Proposed Interpretive Guidance on the Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act (RIN 3038–AD57) and the Proposed Exemptive Order Regarding Compliance with Certain Swap Regulations (RIN 3038–AD85).

GFMA provides comments to U.S. Treasury Secretary Geithner and E.U. Commissioner Barnier regarding extraterritorial legislation. 

The letter is sent in advance of Commissioner Barnier’s trip to the U.S. The letter aims to draw attention to the numerous extraterritorial issues, both new and previously raised, that risk negatively affecting members and their clients.
 

The Global Foreign Exchange Division (GFXD) welcomes the opportunity to comment on the Hong Kong Monetary Authority (HKMA) consultation regarding the Hong Kong Trade Repository (HKTR). On behalf of its members, the GFXD would like to take the opportunity to comment on a number of issues around the implementation of a trade repository for foreign exchange transactions and to continue our recent discussions with you in more detail with the aim of aligning and coordinating development work as closely as possible to the benefit of both regulators and industry.

 GFMA provides comments to the Bank for International Settlements (BIS)and the International Organization of Securities Commissions (IOSCO) on the March 2011 Committee on Payment and Settlement Systems and the Technical Committee of the International Organization of Securities Commissions consultative report on principles for financial market infrastructures.

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.

GFMA and 7 other Associations provide comments to EU Commissioner, Michel Barnier, and Treasury Secretary, Geithner, in relation to extraterritoriality in international regulators’ work on derivatives business.

This is a joint letter on extra‐territorial effects in EU and US regulation of derivatives with International Swaps and Derivatives Association (ISDA), European Banking Federation (EBF), Alternative Investment Management Association (AIMA), Futures and Options Association (FOA), Investment Management Association (IMA), and Wholesale Market Brokers’ Association (WMBA) and London Energy Brokers’ Association (LEBA).