Comment Letters
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FIA Asks U.S. Banking Regulators to Revise Leverage Ratio Proposal (June 13, 2014)
In a comment letter filed on June 13, FIA urged the Federal Reserve and other U.S. banking regulators to revise their proposed supplementary leverage ratio so that it recognizes the risk reduction benefits of central clearing. In particular, FIA urged the regulators to exclude cash segregated for clients in cleared transactions from the total leverage exposure calculation, and to clarify that the exposure for cleared credit derivatives should be based on the measure used for derivatives generally rather than the more stringent measure used for uncleared credit derivatives. 

FIA and Others Seek Guidance on Upfront Payments on Swaps (June 12, 2014)
CME Group, Sifma, ISDA and FIA in a June 12 letter requested that the Treasury Department issue guidance to exempt upfront payments on swaps cleared through a designated clearing organization from rules that would treat them as “significant” non-periodic payments.

FIA Questions ICE Clear Europe Proposal for Covering Losses from Treasury Management (May 16, 2014)

On May 16, FIA submitted a letter to ICE Clear Europe expressing concerns about a proposed mechanism for covering losses incurred by ICE Clear Europe in its treasury management activities. Under this proposal, ICE Clear Europe would set aside $90 million of its own capital to cover such losses, but if this amount is insufficient, ICE Clear Europe would allocate the remainder of the losses to its members. In its letter, FIA commented that the proposed rules, if applied to customer property, would violate certain regulations of the Commodity Futures Trading Commission. FIA also said that the proposed rules would create "undue and potentially unlimited and unquantifiable risk" for ICE members.

Comment Letter

FIA Opposes LCH.Clearnet Proposal for Covering Losses from Treasury Management (April 11, 2014)

On April 11, FIA submitted a letter to LCH.Clearnet Limited expressing opposition to a proposed mechanism for covering losses incurred by LCH.Clearnet in its treasury management activities. Under this proposal, LCH.Clearnet would set aside 15 million euros of its own capital to cover such losses, but if this amount is insufficient, LCH.Clearnet would allocate the remainder to its members. In its letter, FIA commented that the proposed rules, if applied to customer property, would violate certain regulations of the Commodity Futures Trading Commission. FIA also said that the proposed rules would create "undue and potentially unlimited and unquantifiable risk" for members of the clearinghouse.


FIA Submits Comments to Federal Reserve on Bank Commodity Activities (April 9, 2014)

FIA on April 9 submitted a comment letter to the Federal Reserve Board on its advance notice of proposed rulemaking related to activities of financial holding companies related to physical commodities.

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