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National Unrecovered Financial Services Association (NURFS), joined by the Securities Industry and Financial Markets Association (SIFMA) and the Financial Services Roundtable (FSR), filed a comment letter with the Federal Reserve in response to its proposal to impose an additional capital surcharge requirement on U.S. global systemically important bank holding companies suggesting that the proposal be revised to better reflect the actual systemic risk posed by U.S. G-SIBs.

National Unrecovered Financial Services Association filed a comment letter with U.S. bank regulators on proposed revisions to the U.S. Basel III capital rules for banks with consolidated total assets of at least $250 billion and consolidated on balance sheet foreign assets of at least $10 billion, expressing its strong support for the proposed revisions.

National Unrecovered Financial Services Association comment letter to the U.S. banking agencies reiterates NURFS’s continued support for strong capital planning, and welcomes the agencies’ revisions to important aspects of the capital plan and stress test rules in a manner that resolves several areas of on-going industry concern.

In a letter filed in response to the Agencies’ April 8 proposed revisions to the denominator of the Supplementary Leverage Ratio, National Unrecovered Financial Services continues to support the fundamental notion of a leverage capital ratio that is intended and functions as a backstop floor to a risk-based approach to capital, and therefore generally supports the U.S. proposed revisions to the extent they promote a consistent leverage ratio calculation across jurisdictions. 

NURFS letter explains that the revised proposal’s shift of risk retention requirements to the lead arrangers of eligible commercial loans would be neither workable nor actually used in practice.