Letters to Congress

Letter re: FSR CFTC Letter on Swaps Data Reporting and Recordkeeping

May 28, 2014

In a letter filed on May 27 with the Commodity Futures Trading Commission (“CFTC”), FSR urges the commission to make several changes to its swaps reporting rules to decrease duplication and ensure that the commission can focus it resources on analyzing the data points that are most pertinent to trends in the swaps market.

Letter re: FSR Submits Comments on FINRA’s Retrospective Review of Communications and Gifts and Gratuities Rules

May 27, 2014

FSR urges FINRA to adopt more principle-based standards with regards to communications to current and potential broker-dealer clients. FSR also supports reforms to FINRA’s current rules for gifts and gratuities and suggests either a slight increase to the allowable gift limit or the adoption of more principle-based rules that would allow expenses that constitute “ordinary and usual business entertainment.”


Letter re: Comment Period Extension Request on CFPB Privacy Notice Requirements.

May 27, 2014

FSR and three other trade associations request that the CFPB extend that time that it will allow for comments in response to its proposal to amend Regulation P. The proposal, if finalized, would allow alternative delivery methods for the annual privacy notice that banks must send customers under the Gramm-Leach-Bliley Act. Originally, CFPB allowed for a 30-day comment period. The letter urges the CFPB to extend this period by 60 day to allow enough time for affected entities to complete their analysis and formulate comments in response to the proposal.


Letter of Support: H.R. 4167, the Restoring Proven Financing for American Employers Act, 4/29/14

April 29, 2014

H.R. 4167 would exempt CLO assets that were issued before January 31, 2014 from the investment prohibitions of the Volcker Rule and would affirm that investment manager oversight provisions common to the vast majority of CLOs remain permissible. As a result, the bill will ensure that banks can continue to participate in a funding process that is critical to the financing of hundreds of small- and medium-size businesses.


Letter of Support: H.R. 4167, the Restoring Proven Financing for American Employers Act

March 13, 2014

Financial Services Roundtable (“FSR”) supports H.R. 4167, the Restoring Proven Financing for American Employers Act, sponsored by Rep. Andy Barr, and thanks the Committee for its consideration. The bill makes an important improvement to Section 13 of the Bank Holding Company Act (also known as the Volcker Rule) which will aid banking entities in their efforts to provide financing to U.S. companies.

Joint Trade Letter to Chairman Dave Camp re: Tax Proposal, 2/26/14

February 26, 2014

We strongly support your goal to achieve comprehensive tax reform and thank you for your efforts to date. However, in keeping with our support for pro-growth tax reform, we write to strongly oppose the imposition of any arbitrary new tax on financial institutions. A targeted tax on financial institutions, regardless of form or motivation, is misguided and utterly at odds with the fundamental objective of comprehensive tax reform.


FSR/Joint Trades Letter to U.S. Senators on Data Security, 2-5-14

February 5, 2014

Target and Neiman Marcus have testified before the House and Senate about their breaches and, to their credit, have accepted their share of the responsibility and have pledged to work with law enforcement, the financial industry, and Congress to find ways to better protect consumers. Unfortunately, others in the retail industry have not taken this approach. They have made, and continue to make, several misleading and counterproductive statements about the breaches and the position of banks and credit unions across the country. The above bank and credit union organizations would like to set the record straight.

FSR/Joint Trades Letter to U.S. House Members on Data Security, 2-5-14

February 5, 2014

Target and Neiman Marcus have testified before the House and Senate about their breaches and, to their credit, have accepted their share of the responsibility and have pledged to work with law enforcement, the financial industry, and Congress to find ways to better protect consumers. Unfortunately, others in the retail industry have not taken this approach. They have made, and continue to make, several misleading and counterproductive statements about the breaches and the position of banks and credit unions across the country. The above bank and credit union organizations would like to set the record straight.