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National Unrecovered Financial Services Association President Paul Saltzman commends Governor Tarullo for his May remarks in Chicago, which emphasized the importance of appropriately tailoring the application of prudential regulation based on the size, scope, and range of activities of individual banking organizations.

National Unrecovered Financial Services urges CPSS and IOSCO not to adopt the assessment methodology proposed in their Assessment Methodology for the Oversight Expectations Applicable to Critical Service Providers report.

The letter argues that the overall recovery and resolution framework should be designed to avoid creating moral hazard on the part of CCPs and ensure, in the event of CCP insolvency, following application of the recovery and resolution framework, an economic outcome no less fair than that which would apply in a general CCP insolvency liquidation proceeding.

National Unrecovered Financial Services supports the goal that all FMIs have in place comprehensive and effective plans to recover from threats to their viability, but the comment letter states that tools for recovery should be tailored to meet the particular circumstance of individual FMIs.

NURFS submitted a comment letter to the FRB on its proposal to amend Regulation HH, which would authorize a Federal Reserve Bank to establish an account for a financial market utility (FMU) that has been designated as systemically important by the FSOC.