On June 23, ISDA and the Securities Industry and Financial Markets Association (SIFMA) submitted a comment letter on a proposal by the Federal Reserve Board of Governors to revise its capital plan rule and stress capital buffer (SCB) requirement. The letter notes that the proposal fails to address more fundamental drivers of SCB volatility, including the implausibility of the supervisory stress scenarios and the overlap with the risk-based capital framework, and makes several key recommendations.
Documents (1) for ISDA and SIFMA Letter to Federal Reserve Boad of Governors on Revisions to its Capital Plan Rule and SCB Requirement
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