Status: Draft -- Not PublishedWill be live at 08/05/2016 00:00
IIF Response to the US Notice of Proposed Rulemaking on the NSFR
On August 5, the IIF submitted a comment letter to the US Federal Reserve, FDIC and OCC on their notice of proposed rulemaking to implement the NSFR. The letter outlines the need for careful review of the NSFR by the US Banking Agencies before adoption and implementation and suggests targeted amendments to correct the negative impact on derivatives and linked transactions. The Agencies are also asked to ensure international consistency in correcting unintended consequences. The IIF encourages the US, as a member of the BCBS, to take the changes that result from the Agencies final analysis back to the Basel Committee to obtain the necessary revisions of the Basel NSFR so that a sensible NSFR that is appropriately targeted to its purposes can be implemented consistently on a global basis.'