Forum, Trades Support Passage of Diversity Disclosure Legislation

April 20, 2021

The Financial Services Forum and nine other trade associations urge passage of the “Improving Corporate Governance Through Diversity Act of 2021.”

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Trades Back Federal Approach to Support LIBOR Transition

April 14, 2021

The Forum joined other financial trade associations to support federal legislation to address certain legacy contracts that use LIBOR.

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Forum on Member Economic Support During Pandemic

March 9, 2021

Forum outlines how its members are supporting the economy and communities hardest hit by COVID-19 and stresses support for board diversity legislation.

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Joint Trades Letter to Small Business Committees on PPP Extension

March 5, 2021

The Financial Services Forum and nine other trade associations ask leaders of the Senate and House small business committees to request that the SBA clear thousands of PPP application loan holds, as well as to ensure that small business owners who apply by March 31 have full access to the program.

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Forum Supports "Improving Corporate Governance through Diversity Act"

February 24, 2021

The Financial Services Forum is writing in support of the “Improving Corporate Governance through Diversity Act of 2021,” a bill that would require public companies to annually disclose the gender, race, ethnic, and veteran status of their boards of directors, nominees, and senior executives.

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Joint Trades Letter Supporting SLR Extension

February 23, 2021 

The Forum joined other trades in support of the extension of the temporary exclusion of certain assets from the calculation of the Supplementary Leverage Ratio.

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Joint Trades Letter of Support for the National Defense Authorization Act

December 3, 2020 

The Financial Services Forum along with eight other banking and credit union trade associations wrote to the leaders of the U.S. Senate and House Committees on Armed Services to encourage immediate passage of the National Defense Authorization Act, which includes anti-money laundering legislation.

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Joint Trades Request Extension of Comment Period for Notice of Proposed Rulemaking on Fair Access to Financial Services

November 25, 2020

The Forum joined the Bank Policy Institute, American Bankers Association and Consumer Bankers Association in requesting that the Office of the Comptroller of the Currency extend the public commenting period on its Notice of Proposed Rulemaking on Fair Access to Financial Services in light of the rulemaking’s magnitude and potential consequences.

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Forum Joins Coalition Calling for Streamlined PPP Forgiveness

November 19, 2020 The Forum joined a coalition representing thousands of businesses, nonprofits and financial institutions of all sizes in calling on Congress to streamline the overly burdensome Paycheck Protection Program forgiveness process.

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Joint Trades Oppose Financial Transaction Tax Legislation in New Jersey

October 6, 2020 In a letter to the Chairman of the New Jersey General Assembly, joint trade associations expressed their opposition to proposed legislation S.2902/ A.4402, which would effectively represent a sales tax on investors and runs counter to many longstanding policies on promoting savings and economic growth.

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Forum, ABA Comment on Financial Stability Board's Evaluation of "Too-Big-to-Fail" Reforms

September 30, 2020 The Forum along with the American Bankers Association (ABA) submitted a comment letter to the Financial Stability Board (FSB) in response to a June report evaluating too-big-to-fail, or TBTF, reforms. The associations believe that the FSB’s final report should differentiate between jurisdictions and expressly recognize the significant progress made in the U.S. to address TBTF.

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Forum Joins Joint Trades Letter Supporting PPP Funding and Modified Forgiveness

September 29, 2020 The Forum joined nine other trades associations, representing banks, credit unions, community development banks and minority depository institutions, in expressing to Congress unwavering support of additional funding for the Paycheck Protection Program (PPP). In their letter, the trades also urged Congress to modify the overly-complicated PPP loan forgiveness process.

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Coalition of Business, Lender Associations Supports Streamlined PPP Forgiveness

September 17, 2020 The Forum joined more than 100 trade associations in urging Congressional Leadership to pass legislation to streamline forgiveness of the smallest Paycheck Protection Program (PPP) loans. The legislation, S. 4117 and H.R. 7777, will expedite the forgiveness process for the hardest hit businesses on Main Street.

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Joint Trades Comment Letter on Revisions to the Federal Reserve's Capital Assessments and Stress Testing Reports

September 8, 2020 The Forum joined the American Bankers Association and the Securities Industry and Financial Markets Association in offering feedback to the Federal Reserve’s temporary revisions to the Form FR Y-14A/Q/M. The groups offered recommendations to reduce reporting burdens for the banking industry while ensuring the Board’s access to essential COVID-19 response data.

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Forum Joins Coalition Advocating for Streamlined PPP Forgiveness

July 31, 2020 A coalition of more than 140 trade groups representing small business borrowers and lenders sent a letter to congressional leaders advocating for the passage of bipartisan legislation to streamline Paycheck Protection Program forgiveness for the smallest borrowers.

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Joint Trades Push for Passage of the Improving Corporate Governance through Diversity Act of 2019

July 27, 2020 The Financial Services Forum joined 16 other trade organizations in urging the leaders of the U.S. Senate Committee on Banking, Housing, and Urban Affairs to pass the “Improving Corporate Governance through Diversity Act of 2019,” which the House of Representatives passed in a strong, bi-partisan vote in November 2019.

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Forum Joins Banks, Credit Unions in Push for Anti-Money Laundering Legislation

July 20, 2020 The Financial Services Forum joined nine other banking and credit union trade associations in urging the leaders of the U.S. House Committee on Armed Services to include anti-money laundering legislation in the National Defense Authorization Act.

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Forum Joins Coalition Calling for Streamlined PPP Forgiveness for “Main Street” Small Businesses

July 9, 2020 The Financial Services Forum joined a coalition of more than 130 trade groups representing small business borrowers and lenders in a letter to congressional leaders advocating for the passage of bipartisan legislation to streamline Paycheck Protection Program forgiveness for the smallest borrowers.

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Banks, Credit Unions Urge Passage of Anti-Money Laundering Legislation

June 27, 2020 The Financial Services Forum along with nine other banking and credit union trade associations wrote to the leaders of the U.S. Senate Committee on Armed Services to support inclusion of the Anti-Money Laundering Act in the National Defense Reauthorization Act that is currently being debated in Congress.

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Forum Comments on Temporary Change to Supplementary Leverage Ratio

May 29, 2020 The Financial Services Forum comments on an Interim Final Rule from the Federal Reserve to promote the ability of banks to support customers, communities and the economy during the COVID-19 pandemic.

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Banks, Credit Unions Call on SBA to Fix PPP Processing System

The Financial Services Forum joined eight other banking and credit union trade associations in a letter calling on the Small Business Administration to fix the issues surrounding its loan processing program known as E-TRAN, which is the platform for all Paycheck Protection Program application submissions. The sooner this program functions properly, the sooner more small businesses are able to receive the assistance they critically need, the groups wrote.

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Congress Should Exempt Stimulus Payments from Court-Ordered Garnishments

Leading financial services trade associations today wrote Congressional leadership requesting that Congress clarify that the CARES Act economic impact payments (also known as stimulus payments) are treated as benefits subject to the federal exemption from garnishment.

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Additional PPP Funds Needed for Small Businesses, Employees

April 14, 2020 The Financial Services Forum joined the American Bankers Association, Bank Policy Institute, and Consumer Bankers Association in a letter to Congressional leadership calling for Congress to quickly authorize additional funds for the Paycheck Protection Program.

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Forum Submits Comment Letter on Proposed Revisions to Volcker Rule

March 11, 2020 The Financial Services Forum submitted a letter to financial regulators regarding the proposed revisions to the “covered funds” portion of the Volcker Rule. The Forum recommended a few targeted adjustments to eliminate complexity and ensure the final rule promotes economic growth and preserves the safety and soundness of the American financial system.  

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Forum Submits Comment Letter on CFTC Swap Proposal to Ban Existing Market Practice

March 2, 2020 The Financial Services Forum submitted a letter to the Commodity Futures Trading Commission on its proposal to ban a practice in which two parties to a centrally cleared swap transaction reveal their identities after being matched anonymously.  The Forum argued that a ban would pose significant problems for the efficiency and pricing in swaps markets.

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Forum and Other Trade Associations Submit Comment Letter on Proposed Amendments to Margin and Capital Requirements for Covered Swaps Entities

December 9, 2019 The Financial Services Forum and six other financial trade associations submitted a letter to financial regulators regarding the proposed amendments and request for comment on Margin and Capital Requirements for Covered Swap Entities.  In the letter, the groups wrote in support of the regulators’ efforts to foster international and U.S. regulatory harmonization of margin requirements for swaps, specifically the proposal to exempt swaps between affiliates from initial margin requirements.  Such a move would more closely align with those of the CFTC and other G20 regulators, the groups wrote.

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Comment Letter: Forum Advocates for Review of Capital Surcharge in Fed FR Y-15 Proposal Submission

November 13, 2019 The Forum submitted a comment letter regarding a Federal Reserve proposal to expand the quarterly banking organization systemic risk report, the FR Y-15, to collect additional data.  Data from the FR Y-15 are used by the Fed to calculate the GSIB capital surcharge.  In the letter, the Forum suggests that prior to incorporating the new data into the GSIB surcharge calculation, the Fed should first fulfill its commitment to regularly review the GSIB surcharge rule to avoid unintended consequences that could impede economic growth.

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Joint Trades Comment Letter on Regulatory Capital Treatment of TLAC Holdings

October 9. 2019 The Financial Services Forum joined the Bank Policy Institute and the Securities Industry and Financial Markets Association in a letter to federal regulators this week to offer additional recommendations to a proposal on the regulatory capital treatment of advanced approaches firms’ investments in certain unsecured debt instruments of U.S. GSIBs.  The letter is a supplement to the groups’ June comment letter and provides recommendations on how the agencies can further advance the policy objectives of efficiency and simplicity in regulation.

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Trade Groups Support Bipartisan Legislation to End Abuse of Anonymous Shell Companies

September 26, 2019 The Financial Services Forum with eleven other organizations call on leaders of the Senate Banking Committee to act swiftly on the ILLICIT CASH Act, bipartisan legislation to end the abuse of anonymous shell companies. The group said the collection of ownership information “…is critical to law enforcement investigations into organized transnational criminal operations, human trafficking, terrorism financing and other unlawful activity that threaten our national security.”

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Forum, BPI Submit Comments on Two FSB Discussion Papers on Derivatives and Resolution Planning

August 2, 2019 The Financial Services Forum and Bank Policy Institute submitted comments on two Financial Stability Board (FSB) discussion papers regarding 1) the solvent wind-down of derivatives and trading portfolios, and 2) public disclosures on resolution planning and resolvability. Read the full letters HERE and HERE.

Comment Letter: Forum Provides Observations and Recommendations to FSB's Evaluation of “Too-Big-to-Fail” Reforms

June 28, 2019 The Forum sent a comment letter in response to a request for stakeholder feedback from the Financial Stability Board (FSB), which is currently evaluating the effects of reforms that were agreed by the G-20 following the global financial crisis. The Forum wrote that the post-crisis regulatory reforms implemented to address too-big-to-fail in the United States have been successful in addressing systemic and moral hazard risks and policymakers should continue to work to improve efficiency, promote economic growth, and create level playing fields within the global financial system.

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Joint Trades Comment Letter on Regulatory Capital Treatment of TLAC Holdings

June 7, 2019 In a letter to financial regulators, the Forum, along with the Bank Policy Institute and the Securities Industry and Financial Markets Association, offered several recommendations to a proposal on the regulatory capital treatment of advanced approaches firms’ investments in certain unsecured debt instruments of U.S. GSIBs.  The letter offers several recommendations that would allow the final rule to address interconnectedness and other risks relating to a GSIB’s failure more appropriately.  The recommendations would further the policy objectives of efficiency and simplicity in regulation, and would also facilitate the ability of advanced approaches firms to engage in market-making activity, which supports the depth and liquidity of markets for TLAC-eligible debt.

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Joint Trades Letter: Time to Update Inter-Affiliate Initial Margin Requirements

May 13, 2019 To level the playing field for U.S. firms, the Forum, along with six financial trade groups, called on federal regulators to make the current margin rules for both non-cleared and security-based swaps consistent with international standards. Specifically, the group requested that the prudential regulators provide an exception from initial margin requirements for swaps and security-based swaps between affiliates.  

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Joint Trades Letter: Support for H.R. 2513, the "Corporate Transparency Act of 2019”

May 7, 2019

In a letter to House Financial Services Committee Chairwoman Maxine Waters and Ranking Member Patrick McHenry, the Forum and eight financial services trade associations commended the Committee’s work to modernize the anti-money laundering and counterterrorism regulatory system, and urged bipartisan support and swift action on H.R. 2513, the Corporate Transparency Act of 2019.

 

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Comment Letter: Forum Recommends Improvements to New Approach for Measuring Derivatives Exposures

March 18, 2019 The proposed methodology for calculating capital requirements related to derivatives contracts should be improved to increase efficiency and avoid unnecessary costs for customers.

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Comment Letter: Forum Recommends Changes to Improve Volcker Rule

October 17, 2018 In a letter to financial regulators, the Forum commented on proposed changes to the Volcker Rule and made recommendations that would reduce barriers limiting banks’ ability to lend to businesses and households and invest in communities across the country.  The Forum also made recommendations to further streamline the proposal’s compliance regime, while still preserving the original intent of the law.

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Comment Letter: Forum Outlines Recommendations to Improve Resolution Planning Process

September 14, 2018 Large U.S. financial institutions have significantly enhanced their resolvability through the resolution planning process, but the current framework should be improved to promote efficiency, the Financial Services Forum wrote in response to a request for comment from the Board of Governors of the Federal Reserve System (FRB) and the Federal Deposit Insurance Corporation (FDIC) on the resolution planning, or “living wills,” process.

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Congressional Testimony: Forum Supports Capital Rules Review

July 17, 2018 Financial Services Forum President and CEO Kevin Fromer testified before the House Financial Services Subcommittee on Financial Institutions and Consumer Credit and explained how the Forum supports the systematic review of U.S. capital rules to ensure the regulatory system balances the important goals of a safe and sound financial system with one that best supports economic growth and job creation.

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Comment Letter: Federal Reserve Proposal to Establish Stress Capital Buffer

June 25, 2018 The Forum sent a comment letter to the Board of Governors of the Federal Reserve System on its proposal to integrate its regulatory capital rule with its capital planning and stress testing rules while establishing a new stress capital buffer. In the letter the Forum made the following points:

  • Integration of the stress testing and capital regimes to achieve a more unified and simplified capital regime is a laudable goal, but the Federal Reserve should undertake a broader review of its capital and stress testing programs to ensure that boards of directors at financial institutions can clearly and appropriately make capital management decisions; and
  • The proposal underscores the need for the Federal Reserve to enhance the transparency of its stress testing models and scenarios designs.
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Comment Letter: Federal Reserve, Office of the Comptroller of the Currency Proposal to Modify Enhanced Supplementary Leverage Ratio

June 25, 2018 The Forum sent a comment letter to the Federal Reserve and the Office of the Comptroller of the Currency (OCC) on their proposal to modify the enhanced supplementary leverage ratio. In the letter the Forum made the following points:

  • The effort by the Federal Reserve and OCC to recalibrate the rule is positive, but the leverage calculations should exclude risk-free assets to eliminate the economic incentive to reduce participation in lower-risk, lower-return businesses;
  • The agencies should take additional steps to ensure that leverage capital requirements act as a backstop to risk-based capital requirements, rather than as a binding constraint; and
  • As part of their broader review, the agencies should evaluate the “gold-plating” of international regulatory standards in the United States, which has led to much higher capital standards in the United States than in other countries, harming the international competitiveness of U.S. banks relative to their global peers.
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