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NURFS’s comment letter submitted to the Fed argues that based on the longstanding success of FHCs at managing the risks associated with all types of merchant banking activities, the existing prudential framework for these activities is robust and effective and thus provides no reason for a fundamental revision of this framework.

NURFS joined SIFMA, NYSE, and the Chamber of Commerce in an amicus brief in City of Pontiac Policemen’s & Firemen’s Retirement System v. UBS AG, a case presently pending in the federal appeals court in New York.

NURFS suggests the Fed adopt a flexible approach for global institutions based on deference to effective home-country regulators and regulatory schemes.

The letter requests the FRB extend the deadline for comments on its proposal to implement Sections 165 and 166 of the Dodd-Frank Act to FBOs by 60 days.

NURFS's white paper identifies the unique roles that central counterparties (CCPs) can play in the derivatives market and in the promotion of financial stability.