As of yesterday, the Federal Reserve Board (FRB) was still posting comment letters to its website re: the Financial Holding Company (FHC) commodities activities Notice of proposed rulemaking (NOPR).1 These include letters dated Tuesday of last week. That’s slow. Based on the comments so far (really hope they are all posted now), between 76 to more than 79% of commenters are against proposals contained in the NOPR, depending on how you tally the responses. There are 46 submissions listed on the FRB site. These include some letters submitted as follow-ups to prior submissions, as well as some letters that were submitted jointly by various organizations or individuals. To be conservative and not count follow-up letters (or separate letters submitted by those who initially submitted jointly), one could say that there were expressions of 39 viewpoints submitted to the FRB, 30 of which (over 76%) were opposed to proposals in the NOPR. A better way to tally the submissions may be to separately count each of those that filed as part of any joint submission. When this is done, one ends up with a list of 64 commenters, 51 of which (over 79%) are opposed to the proposals in the NOPR. The details of such a tally are shown in the table below. Where an entity was part of more than 1 joint submission, e.g., Institute of International Bankers, who jointly signed with SIFMA and with The Clearinghouse Association, such entity was counted once. The letters referenced in the table are hyperlinked.
| Name | View | Comments |
| Accuride Corporation | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Air Products and Chemicals, Inc. | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Alon | con | LETTER DATED February 20, 2017 |
| American Bankers Association | con | JOINT LETTER AMONG Clearing House Association L.L.C., the American Bankers Association, the Financial Services Forum, the Financial Services Roundtable and the Institute of International Bankers, February 21, 2017 |
| American Investment Council | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| American Public Gas Association | con | LETTERS DATED December 19, 2016 & February 20, 2017 |
| American Wind Energy Association | con | LETTER DATED December 19, 2016 |
| Ball Corporation | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Barrick Gold | con | LETTERS DATED December 7, 2016 & February 17, 2017 |
| Black Belt Energy Gas District | con | LETTER DATED February 21, 2017 & JOINT LETTER WITH Clarke Mobile Counties, December 16, 2016 |
| BP | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Bradley Byrne, Member, House of Rep | con | LETTER DATED December 22, 2016 |
| Calpine | con | LETTER DATED December 13, 2016 |
| Central Plains Energy Project | con | LETTER DATED February 21, 2017 |
| Cheniere Energy, Inc. | con | LETTER DATED February 20, 2017 |
| City of Rocky Mount, NC | con | LETTER DATED February 20, 2017 |
| Clarke-Mobile Counties Gas District | con | LETTER DATED February 21, 2017 & JOINT LETTER WITH Black Belt Energy Gas Districts, December 16, 2016 |
| Clearing House Association L.L.C. | con | JOINT LETTER AMONG Clearing House Association L.L.C., the American Bankers Association, the Financial Services Forum, the Financial Services Roundtable and the Institute of International Bankers, February 21, 2017 |
| Cogentrix | con | LETTER DATED December 20, 2016 |
| Delek US Holdings | con | LETTER DATED February 20, 2017 |
| Edison Electric Institute | con | JOINT LETTER WITH National Rural Electric Cooperative Association February 20, 2017 |
| Financial Services Forum | con | JOINT LETTER AMONG Clearing House Association L.L.C., the American Bankers Association, the Financial Services Forum, the Financial Services Roundtable and the Institute of International Bankers, February 21, 2017 |
| Financial Services Roundtable | con | JOINT LETTER AMONG Clearing House Association L.L.C., the American Bankers Association, the Financial Services Forum, the Financial Services Roundtable and the Institute of International Bankers, February 21, 2017 |
| FMC Corporation | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Futures Industry Association | con | LETTER DATED February 17, 2017 |
| General Electric Company | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Goldman Sachs Group | con | LETTER DATED February 21, 2017 |
| Greenville Utilities Commission | con | LETTER DATED December 29, 2016 |
| Harley-Davidson, Inc. | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Honeywell International | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Institute of International Bankers | con | JOINT LETTER AMONG Clearing House Association L.L.C., the American Bankers Association, the Financial Services Forum, the Financial Services Roundtable and the Institute of International Bankers, February 21, 2017 & JOINT LETTER with SIFMA dated February 17, 2017 |
| International Energy Credit Association | con | LETTER DATED February 20, 2017 |
| International Swaps and Derivatives Association, Inc. | con | LETTER DATED February 17, 2017 |
| National Association of Corporate Treasurers | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| National Mining Association | con | LETTERS DATED December 9, 2016 & February 17, 2017 |
| National Rural Electric Cooperative Association | con | JOINT LETTER WITH Edison Electric Institute February 20, 2017 |
| Natural Gas Supply Association | con | LETTER DATED December 15, 2016 |
| NextEra Energy Resources LLC | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Northern Virginia Electric Cooperative | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Novelis | con | LETTER DATED December 21, 2016 |
| Orbital ATK, Inc. | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Philadelphia Energy Solutions | con | LETTER DATED December 20, 2016 |
| Public Utility District No. 1 of Chelan County, Washington | con | LETTER DATED December 22, 2016 |
| Securities Industry and Financial Markets Association | con | JOINT LETTER WITH Institute of International Bankers February 17, 2017 |
| Southwest Airlines Co. | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Tennessee Energy Acquisition Corporation | con | LETTER DATED February 21, 2017 |
| The Boeing Company | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| The Hershey Company | con | JOINT LETTER UNDERSIGNED BY 16 ENTITIES February 20, 2017 |
| Town of Slaughter, Louisiana | con | LETTER DATED February 21, 2017 |
| TrailStone Group | con | LETTER DATED December 22, 2016 |
| U.S. Chamber of Commerce | con | LETTER DATED January 5, 2017 |
| Amazon Watch | pro | LETTER DATED December 20, 2016 |
| Americans for Financial Reform | pro | LETTER DATED February 23, 2017 |
| Better Markets | pro | LETTER DATED February 17, 2017 |
| Elise J. Bean | pro | JOINT LETTER DATED December 22, 2016 |
| Exante Regulatory Compliance Consultants | pro | SUBMISSION DATED December 19, 2016 |
| Institute for Agriculture and Trade Policy | pro | LETTER DATED December 21, 2016 |
| Jack Reed | pro | JOINT LETTER DATED February 9, 2017 |
| James D. Hanson | pro | SUBMISSION DATED November 24, 2016 |
| Jeff Merkley | pro | JOINT LETTER DATED February 9, 2017 |
| Public Citizen | pro | LETTER DATED February 10, 2017 |
| Saule Omarova | pro | LETTER DATED February 14, 2017 |
| Sherrod Brown | pro | JOINT LETTER DATED February 9, 2017 |
| Tyler E. Gellasch | pro | JOINT LETTER DATED December 22, 2016 |
| Reid B. Stevens and Jeffery Y. Zhang | other | paper dated December 21, 2016 |
- Federal Reserve System, Regulations Q and Y; Risk-Based Capital and Other Regulatory Requirements for Activities of Financial Holding Companies Related to Physical Commodities and Risk-Based Capital Requirements for Merchant Banking Investments, Notice of proposed rulemaking, 81 Fed. Reg. 67220 (Sep. 30, 2016), avail. at https://www.gpo.gov/fdsys/pkg/FR-2016-09-30/pdf/2016-23349.pdf