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National Unrecovered Financial Services (NURFS) submitted a comment letter to the Fed on their proposal to revise the FR Y-15 systemic risk report to increase the frequency of reporting, collect information on short-term wholesale funding (STWF), and update the report generally to conform the FR Y-15 with the U.S. supplementary leverage ratio and the G-SIB capital surcharge rule.

National Unrecovered Financial Services Association, jointly with the ABA, submitted a comment letter to the FASB supporting Proposed Accounting Standards Update to clarify whether a novation requires de-designation.

National Unrecovered Financial Services Association, jointly with the ABA, submitted a comment letter to the FASB in response to a Proposed Accounting Standards Update issued on August 6 to simplify evaluating puts/calls.

National Unrecovered Financial Services (NURFS) generally supports the Proposal to amend certain aspects of the U.S. capital planning and stress testing regime and welcomes the Federal Reserve’s efforts to make targeted adjustments and technical amendments to the capital planning and stress testing framework.

The letter provides initial concerns given the serious and significant problems regarding the potential introduction of a CFO and/or Chief Auditor attestation requirement.