The Latest: Why the Basel III Endgame Must be Re-Proposed
In this episode of The SIFMA Podcast, SIFMA's Chief Operating Officer Joseph Seidel sits down with Dr. Peter Ryan, Managing…
Testimony on Stress Testing: What’s Inside the Black Box
SIFMA submitted a written testimony to the U.S. House of Representatives’ Financial Institutions and Monetary Policy Subcommittee regarding the supervisory…
Basel III Endgame Blog Series
SIFMA’s prudential regulation blog series on the impact of U.S. bank capital requirements on the capital markets.
Long-Term Debt Requirements for Large Bank Holding Companies, Certain Intermediate Holding Companies of Foreign Banking Organizations, and Large Insured Depository Institutions (SIFMA and SIFMA AMG)
SIFMA and SIFMA AMG provided supplemental comments to the Board of Governors of the Federal Reserve System, Office of the…
Our Take on PwC’s Assessment of the US Basel III Endgame Proposal
In this post, SIFMA's Guowei Zhang dives into PwC's two-part study on the Basel III Endgame and highlights why the…
Why the Basel III Endgame Must Be Re-Proposed
In this episode of The SIFMA Podcast, SIFMA's Joseph Seidel, Chief Operating Officer, and Dr. Peter Ryan, Managing Director, Head…
How the US GSIB Surcharge and Basel III Endgame Proposals Impair Client Clearing of OTC Derivatives
This post in our Basel III Endgame blog series highlights why client-cleared OTC derivatives should be excluded from the GSIB…
10 Recommendations to Revise the Basel III Endgame Proposal
Opening remarks by Joseph Seidel, Chief Operating Officer for SIFMA, as prepared for delivery at SIFMA’s Basel III Endgame Roundtable.
Why the Federal Reserve Should Pay Particular Attention to Banks’ Capital Markets Activities When Deliberating Revisions to the Basel III Endgame Proposal
SIFMA's Dr. Guowei Zhang explains why the Federal Reserve should closely consider the effects on banks' capital markets businesses when…
Proposed Agency Information Collection Activities; Comment Request (SIFMA and ISDA)
SIFMA and The International Swaps and Derivatives Association, Inc. (ISDA) provided comments to the Office of the Comptroller of the…
SIFMA Submits Comments to Federal Reserve on FBO Resolution Proposal
Washington, D.C., November 30, 2023 – SIFMA submitted a letter to Board of Governors of the Federal Reserve System (Federal…
Joint Trades Request for Interim Extension of the July 2024 Submission Date for Triennial Filers
SIFMA along with the Bank Policy Institute (BPI), American Bankers Association (ABA), and Institute of International Bankers (IIB), submit this…
Proposed Guidance for Resolution Plan Submissions of Foreign Triennial Full Filers
SIFMA provided comments to the Board of Governors of the Federal Reserve System (Federal Reserve) and the Federal Deposit Insurance…
How the Basel III Endgame Could Impair Securitization Markets and Harm US Businesses and Consumers
The U.S. Basel III Endgame (“B3E”) proposal related to securitization prescribes the most restrictive approach to set capital requirements for…
The Federal Reserve Should Remove “Gold-Plating” in the Basel III Endgame
This blog, part of our series on prudential regulation, identifies areas in which the U.S. proposal gold-plates the international standards…
A Rejoinder on the Need for Trading Book Capital Increases
In this blog post, SIFMA's Dr. Peter Ryan and Dr. Gowei Zhang highlight three claims in Vice Chair Barr’s speech…
The Federal Reserve Should Revise the US GSIB Surcharge Methodology to Reflect Real Risks and Support the Economy
In this joint post with BPI and FSF, we explain how the U.S. methodology for assessing a capital surcharge on…
Full Committee Markup of S.2860, the SAFER Banking Act
Senate Committee on Banking, Housing, and Urban Affairs Full Committee Markup Wednesday, September 27, 2023 Topline The Senate Committee on…
A Holistic Review of Regulators: Regulatory Overreach and Economic Consequences
House Committee on Financial Services Subcommittee on Financial Institutions and Monetary Policy A Holistic Review of Regulators: Regulatory Overreach and…
Implementing Basel III: What’s the Fed’s Endgame
House Financial Services Committee Subcommittee on Financial Institutions and Monetary Policy Implementing Basel III: What’s the Fed’s Endgame Thursday, September…
Understanding the Proposed Changes to the US Capital Framework
In Part VI of this blog series, we examine which of the Basel III Endgame proposal’s three capital stacks are…
The Impact of the Basel III Endgame on US Capital Markets: A Video Blog
Prudential rules have made the financial system safer and stronger. In fact, recent studies have found capital levels in the…
SIFMA, Joint Trades Letter to Federal Chair Powell on Costs of Higher Capital
Washington, D.C. – SIFMA joined The Bank Policy Institute, American Bankers Association, Financial Services Forum and the Institute of International…
SIFMA Statement on US Implementation of the Basel III Endgame
Washington, D.C., July 10, 2023 – SIFMA today issued the following statement from president and CEO Kenneth E. Bentsen, Jr.…
Identifying an Optimal Level of Capital and Evaluating the Impact of Higher Bank Capital Requirements on US Capital Markets
In this, the third of a series of blog posts on U.S. bank capital requirements, we discuss what the "optimal”…
SIFMA Statement on FSOC Nonbank SIFI Designation Proposal
Washington, D.C., April 21, 2023 – SIFMA today issued the following statement from SIFMA’s Asset Management Group (SIFMA AMG) regarding…
Proposed Guidance for New York State Regulated Banking and Mortgage Organizations Relating to Management of Material Financial Risks from Climate Change (SIFMA and IIB)
SIFMA and the Institute of International Bankers (IIB) provided comments to the New York State Department of Financial Services (NYDFS)…
Understanding the Current Regulatory Capital Requirements Applicable to US Banks
In this, the first of a series of blogs on prudential requirements and their impacts, we discuss revisions to bank…
Withholding on Transfers of Interests in PTPs
SIFMA provides comments to the Internal Revenue Service (IRS) and the Treasury Department (Treasury) in response to Notice 2023-8 regarding…
Draft Instructions for Form 1042-S (2023)
SIFMA provided comments to the Internal Revenue Service (IRS) on the draft 2023 Instructions for Form 1042-S (Draft Instructions).
HFSC Prudential Hearing
House Committee on Financial Services Oversight of Prudential Regulators: Ensuring the Safety, Soundness, Diversity, and Accountability of Depository Institutions Wednesday,…
US Stress Test Capital Requirements Are Excessively Volatile and Overestimate Losses
Since their initiation in late 2010, the CCAR and DFAST processes have become the cornerstones of the regulatory capital framework…
Principles for Climate-Related Financial Risk Management for Large Financial Institutions
SIFMA and ISDA provided comments to the Federal Deposit Insurance Company (the FDIC) request for feedback on the Principles for…
SIFMA Responds to Federal Reserve Paper on Central Bank Digital Currencies
Washington, D.C., May 20, 2022 – In a letter responding to the recent discussion paper published by the Board of…
CBDC Discussion Paper Response
SIFMA provided comments to the Federal Reserve on the recent discussion paper published by the Board of Governors of the…
Feedback Request on the Principles for CRFRM
SIFMA and the International Swaps and Derivatives Association, Inc. (ISDA) provided comments on the Office of the Comptroller of the…
Improving Capacity and Resiliency in US Treasury Markets: Part III
In Part III of this blog series, we discuss the potential benefits and costs of moving more segments of the…
Consultative Document on the Prudential Treatment of Cryptoasset Exposures
SIFMA provided comments to the Basel Committee on Banking Supervision’s (“Basel Committee”) consultative document on the “Prudential treatment of cryptoasset…
A Guide to FRTB and Why It’s Important
In this podcast, SIFMA's Chief Operating Officer, Joseph Seidel, sits down with Peter Ryan, Head of International Capital Markets and…
The Fundamental Review of the Trading Book (FRTB): An Introductory Guide
In this in-depth introduction to the Fundamental Review of the Trading Book (FRTB), our team explains what it was designed…
Joint Trades on US-China Phase One Trade Agreement
SIFMA and joint trade associations provided comments to Treasury and USTR in support of continued engagement with China on trade…
Proposed Guidelines for Evaluating Account and Services Requests
SIFMA provided comments to the Board of Governors of the Federal Reserve System on the notice regarding proposed guidelines to…
Joint Letter on Call Report and FFIEC 002 Deposit-Related Revisions
SIFMA, the American Bankers Association (ABA), and the Bank Policy Institute (BPI) provided comments on the proposal by the Board…
Improving Capacity and Resiliency in US Treasury Markets: Part II
In Part II of this blog series, we discuss a variety of ideas stemming from growing calls to reform the…
Improving Capacity and Resiliency in US Treasury Markets: Part I
In Part I of this blog series, we provide an overview of the critical role of the U.S. Treasury markets…
Extending the Supplemental Leverage Ratio is Essential to Main Street
SIFMA believes there is a definitive need to extend the interim final rule (IFR) for bank holding companies that provides…
Final Regulations of Section 1446(f) Relating to Transfers of Interests in Publicly Traded Partnerships
SIFMA provided comments on the final regulations under section 1446(f)2 relating to transfers of interests in publicly traded partnerships (“PTPs”)…
SIFMA Comment on Need for Extension of SLR Exclusion
Washington, D.C., February 23, 2021 – SIFMA today submitted a comment letter to the Federal Reserve System regarding the need…
Extension of Exclusion from the Supplementary Leverage Ratio
SIFMA provided comments to the Board of Governors of the Federal Reserve System’s (the “Federal Reserve's”) interim final rule (the…
Federal Reserve’s Off Cycle Stress Test Is Most Severe Stress Test Ever, Punishes Capital Market Activity
Key Takeaways Despite positive economic trends noted in early June, the application of a rigorous stress test in February 2020,…
Joint Trades on LISCC Draft SR Comment Letter
SIFMA and joint trades provided comments on the draft SR Letter issued by the Board of Governors of the Federal…
Capital Planning and Stress Testing Requirements for Large Bank Holding Companies, Intermediate Holding Companies, and Savings and Loan Holding Companies
SIFMA provided comments on the notice of proposed rulemaking (the “Proposal”) issued by the Board of Governors of the Federal…
Finalized NSFR: Could Have Been Better, Could Have Been a Lot Worse
Key Takeaways on Final NSFR Rule Implementation date is July 21, 2021 Increased harmonization with Basel Standard and parts of…
Implementing the Net Stable Funding Ratio: Considerations as U.S. Regulators Look to Finalize the Long-Term Liquidity Requirement
Next week on October 20th, the federal banking agencies will publish the finalized Net Stable Funding Ratio (NSFR) rule. The…
Evaluation of the Effects of Too-Big-to-Fail Reforms Consultation Paper
GFMA provided comments on the Financial Stability Board’s Evaluation of the effects of too-big-to-fail reforms. We commend the FSB for…
Joint Trades on the Proposed Agency Information Collection Activities – Capital Assessments and Stress Testing Reports
SIFMA and joint trades provided comments on the temporary approval of information collection by the Board of Governors of the…
Resolution Planning for Large International Banks: Considerations for the Federal Reserve and the FDIC
Key Takeaways In early March, the Federal Reserve and Federal Deposit Insurance Corporation (FDIC) issued proposed resolution planning guidance for…
The View from Washington: Special Edition
In this video series, we gather the most influential voices shaping today’s capital markets to examine the client first focus,…
The COVID-19 Stress Tests: Considerations for the Federal Reserve as it Develops an Unprecedented Second Round of Tests
When the Federal Reserve (”the Fed”) issued the results of its 2020 stress tests (which included a COVID-19 “sensitivity analysis”),…
Unpacking the Federal Reserve’s COVID-19 Sensitivity Analysis
The analysis was severe; the Fed should avoid punitive assumptions in the next round of submissions to promote economic recovery…
SIFMA Statement on CCAR 2020 Results
Washington, D.C., June 25, 2020 – SIFMA today released the following statement from Kenneth E. Bentsen, Jr., SIFMA president and CEO,…
Outline of Changes to CCAR 2020 Provides Needed Clarity
Earlier today, Federal Reserve Vice Chairman Randal Quarles outlined the recent changes in the upcoming Dodd Frank Annual Stress Testing…
Peter Ryan Joins SIFMA as Head of International Capital Markets and Prudential Policy
Washington, D.C., June 11, 2020 – SIFMA today announced Peter J. Ryan has been appointed managing director and head of…
Podcast: CCAR 2020 During COVID-19: The Fed Should Stay the Course
Results of the Comprehensive Capital Analysis and Review (CCAR) are expected to be announced on June 25. SIFMA has repeatedly…
Guidance for Resolution Plan Submissions of Certain FBOs
SIFMA provided comments the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation for feedback…
New SIFMA Analysis: The Fed & CCAR 2020 – Stay the Course for the Sake of Economic Recovery
Comprehensive Capital Analysis and Review (CCAR) results are expected to be announced within the next month. As noted in our…
Senate Banking Committee Hearing on the Implementation of Title IV of the CARES Act
Senate Committee on Banking, Housing, and Urban Affairs “Implementation of Title IV of the CARES Act” Tuesday, June 2, 2020…
Joint Trades on Guidance for Resolution Plan Submissions of Certain FBOs
SIFMA and joint trades provided comments to the Federal Reserve System and the Federal Deposit Insurance Corporation regarding feedback on…
Temporary Exclusion from the Supplementary Leverage Ratio
SIFMA provided comments to the Federal Reserve on the Federal Reserve Board of Governors System's interim final rule providing a…
Revisiting the Fed’s CCAR Scenario: A Case for Self-Fulfilling Prophecy
With all U.S. states in various phases of reopening, and some positive developments regarding COVID-19 virus containment, there is no…
House Financial Services Subcommittee Roundtable Examining the Impacts of the COVID-19 Pandemic on U.S. Capital Markets
House Financial Services Subcommittee on Investor Protection, Entrepreneurship, and Capital Markets “Virtual Roundtable – Examining the Impacts of the COVID-19…
Proposal Revising Brokered Deposits Restrictions
SIFMA provided comments to the FDIC on revising its regulations implementing section 29 of the Federal Deposit Insurance Act, which…
Brookings Insitution Event with Fed Chair Powell
Brookings Institution Federal Reserve Chair Jerome Powell on COVID-19 and the Economy Thursday, April 9, 2020 Opening Remarks Participants: John…
SIFMA Supports Proposed Changes to the Volcker Rule
Washington, D.C., March 11, 2020 – SIFMA today filed a comment letter on the proposed revisions to the Volcker Rule…
Proposed Revisions to the Volcker Rule
SIFMA provided comments on the proposed rule to revise the regulations implementing Section 13 of the Bank Holding Company Act…
Federal Reserve Bias Against Capital Markets Not Based on Facts and Not Good for US
Consciously or unconsciously, the Federal Reserve’s rules treat capital markets activities as riskier than commercial bank lending.
Credit Valuation Adjustment Risk
SIFMA provided comments to the Bank for International Settlements on Basel Committee on Bank Supervision's recent Consultative Document- Credit Valuation…
Podcast: Concerns Remain Regarding Global Market Shock Component in 2020 Stress Tests
Earlier this month, the Federal Reserve published its “2020 Supervisory Scenarios for the Annual Stress Tests Required under the Dodd…
2020 GMS Moving in the Right Direction But More To Be Done
Late last week, the Federal Reserve published its “2020 Supervisory Scenarios for the Annual Stress Tests Required under the Dodd…
SIFMA Statement on Federal Reserve Finalization of Control Rules
Washington, D.C., January 30, 2020 – SIFMA today released the following statement from Kenneth E. Bentsen, Jr., SIFMA president and CEO,…
SIFMA Statement on Proposed Revisions to the Volcker Rule
Washington, D.C., January 30, 2020 – SIFMA today issued the following statement from Kenneth E. Bentsen, Jr., president and CEO,…
Quarles Sets the Stage for Changes to Increase Transparency and Fairness of Fed Oversight Regime
On Friday, Vice Chairman for Supervision of the Federal Reserve, Randal Quarles, laid out a suite of changes he intends…
Podcast: Changes on the Horizon for the Federal Reserve’s Oversight Regime
In a speech delivered on Friday, January 16, Vice Chairman for Supervision of the Federal Reserve, Randal Quarles, laid out…
Podcast: Living Will Process and Impact on US Capital Markets
The Dodd-Frank Act requires large financial institutions to submit resolution plans. In this podcast, we discuss the evolution of the…
Federal Deposit Insurance Corporation Open Meeting on SA-CCR
Federal Deposit Insurance Corporation Board of Directors Open Meeting Tuesday, November 19, 2019 Key Topics & Takeaways The FDIC Board…
Challenges regarding the implementation of the FBO Tailoring Rule
SIFMA provided comments to the Board of Governors of the Federal Reserve regarding the tailored application of interagency liquidity and capital…
Joint Comments on FBO Tailoring Rules
SIFMA and joint trades provided comments and requests for clarification with respect to the final tailoring rules issued by the…
House Financial Services Subcommittee Hearing on Stock Buybacks
House Financial Services Subcommittee on Investor Protection, Entrepreneurship, and Capital Markets “Examining Corporate Priorities: The Impact of Stock Buybacks on…
Podcast: Are CCAR Shocks to the Trading Book Plausible?
A statistical analysis of stress testing scenarios answers a seemingly simple question.
GILTI Regulations
SIFMA sent comments to the IRS regarding the regulations under section 951A that were issued on June 21, 2019. The…
Global Market Shock and Large Counterparty Default Study
Recommendations for Reforms Based on a Statistical Analysis of Stress Testing Scenarios In this white paper, we apply statistical analysis…
SIFMA and Financial Services Forum Submit Comments on Federal Reserve Board Control Proposal
Washington, D.C., July 15, 2019 – The Securities Industry and Financial Markets Association (SIFMA) and the Financial Services Forum today…
FRB Controls and Divestiture Proceedings
SIFMA and The Financial Services Forum sent comments to the Board of Governors of the Federal Reserve System (the “FRB”)…
Proposed Regulations Under Section 1446(f)
SIFMA commented on the proposed regulations under section 1446(f) of the Internal Revenue Code. The proposed 1446(f) regulations impose a…
FASB Accounting Standards Update Disclosure Improvements
SIFMA commented to the Financial Accounting Standards Board’s on the proposed Accounting Standards Update Disclosure Improvements: Codification Amendments in Response…
No-action Relief for Certain Bank Sweep Receivables Under Rule 15c3-1
The Capital Steering Committee of SIFMA is writing to request assurances that the staff of the Division of Trading and…
Prudential Conference Debrief, 2019
Recently, SIFMA hosted its annual Prudential Regulation Conference. With a day of presentations and events and around 200 attendees, we…
Belt, Suspenders and Regulatory Noose: The Need for a Holistic Review of Prudential Regulation
With the adoption of numerous conservative prudential regulatory requirements, banks now hold excessive levels of capital and liquidity that are…
Liquidity Standards for Large Banking Organizations
SIFMA sent comments on the following proposals by the federal banking agencies related to liquidity standards for large banking organizations:…
Applicability of Enhanced Prudential Standards for Foreign Banking Organizations
SIFMA sent comments on the following proposals by the federal banking agencies to revise the enhanced prudential standards that apply…
Response to the FSB’s consultation on evaluation of too-big-to-fail reforms for banks
SIFMA’s global affiliate, GFMA provides comment to the Financial Stability Board (FSB) on their consultation on the effects of the…
Joint Trades on the Proposed Rulemaking for IDI Rule
The Bank Policy Institute, the Securities Industry and Financial Markets Association and the American Bankers Association (together, the Associations) appreciate…
Joint Trades on the Proposed 165(d) Rule Amendments
The Bank Policy Institute (BPI), the Securities Industry and Financial Markets Association (SIFMA) and the American Bankers Association (ABA and,…
Joint Trades on Regulatory Capital Treatment of TLAC Holdings
SIFMA, the Bank Policy Institute (BPI), and the Financial Services Forum (FSF) provide comments to the Office of the Comptroller…
Remarks as Prepared for SIFMA and BPI’s 2019 Prudential Regulation Conference – Joe Seidel, SIFMA
Over the last several years, the financial industry has been focused on working to build up capital to enhance the…
Podcast: The State of the Post-Crisis Prudential Regulatory Framework and Its Effect on Capital Markets
With the adoption of complex, conservative, prudential regulatory requirements, banks are now subject to multiple risk-based capital ratios, leverage ratios,…
Resolution Plans Requirements of Section 165(d) – Proposal and Timing for Foreign Banking Organizations
SIFMA, the Institute of International Bankers (IIB) and the Bank Policy Institute (BPI) submit comments to the to Board of…
Resolution Plans Requirements of Section 165(d) – Proposal and Timing for December 2019 Filers
SIFMA and the Bank Policy Institute (BPI) submit comments to the to Board of Governors of the Federal Reserve System…
OCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches
SIFMA and the Bank Policy Institute (BPI) provide comments to the Office of the Comptroller of the Currency (the OCC) on…
Agency Information Collection Activities: Proposed Collection Renewal; Comment Request (OMB No. 3064–0185)
SIFMA and the Bank Policy Institute (BPI) provide comments to Federal Deposit Insurance Corporation (FDIC) and Office of Information and…
Resolution Planning Guidance for Eight Large, Complex U.S. Banking Organizations
SIFMA and the Bank Policy Institute (BPI) provided comments to the Board of Governors of the Federal Reserve System (Federal…
Federal Reserve System eSLR and TLAC Proposal
SIFMA and other associations provided comments to the Federal Reserve on their proposal to revise the enhanced supplementary leverage ratio…
Proposed Amendments to the Regulatory Capital, Capital Plan and Stress Test Rules
SIFMA and other associations provided comments to the Federal Reserve System on a proposal to establish a stress buffer framework that…
Hong Kong Monetary Authority’s Consultation Paper on Loss-Absorbing Capacity Requirements for Authorized Institutions
SIFMA and TCH provide comments to the Hong Kong Monetary Authority on proposed rules on loss-absorbing capacity requirements for authorized institutions. See…
Senate Banking Committee Executive Session
Senate Banking Committee Executive Session Tuesday, December 5, 2017
Proposed Amendments to EU Law Affecting Global Financial Stability
SIFMA and The Clearing House (TCH) provide comments alerting the Financial Stability Oversight Council (FSOC) to a pending proposal to revise…