8 out of 20 commenters to the Federal Reserve Board (FRB) on its proposed rules for QFCs of GSIBs expressed concern that the FRB is treading on legislative terrain or otherwise acting outside of its authority.1 This is an update as 3 more commenters’ submissions were finally posted today. Prior to today, only 17 submissions were being shown. For some reason, the FRB did not post all commenters’ submissions immediately. While some submissions were posted promptly, others took more than a week to appear.
1 See comments filed in response to Federal Reserve Board’s Proposed Rule entitled Restrictions on Qualified Financial Contracts of Systemically Important U.S. Banking Organizations and the U.S. Operations of Systemically Important Foreign Banking Organizations; Revisions to the Definition of Qualifying Master Netting Agreement and Related Definitions, 81 Fed. Reg. 29190 (May 11, 2016).
(2016 Aug 19, 8-36 AM) update: 21 submissions now shown. A 2nd letter from DPW was submitted to add BOA to accompany CITI, Goldman, JPM and MS, on whose behalf DPW commented.
(2016 Aug 22, 11-49 AM) update: 23 submissions now shown as end of last week (really just 22, as 1 by DPW is just an update).
(2016 Aug 26, 2-28 PM) update: a supplemental letter dated Aug 23 from the State of Wisconsin Investment Board (SWIB) has been posted. It is focused on an issue of no small moment, as identified in the screen capture below:
