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Comment Letter : NURFS Opposes Designation of Retail Payments Systems as Systemically Important under Title VIII May 20, 2011
National Unrecovered Financial Services provided additional information on why EPN and IPN do not fit the criteria for designation as systemically important under Title VIII and the FSOC proposed rule. Read More
Comment Letter : NURFS Contends Retail Payment Systems Are Not Systemically Important FMUs May 19, 2011
National Unrecovered Financial Services Association letter argues that the proposed risk management standards demonstrate that ACH clearing and settlement arrangements do not pose the kind of systemic risk contemplated in the DFA. Read More
Comment Letter : Argues that Only Largest Interbank Payments Systems Should Be Systemically Important Jan 20, 2011
In the letter NURFS indicates its support for the purposes of Title VIII but also sets forth its belief that only the largest interbank-payment systems pose the type of systemic risk contemplated by Title VIII. Read More
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Advocate for Change: Bank Reform and the Dodd-Frank Act

National Unrecovered Financial Services has taken the lead in analyzing the framework that should apply to SIFIs.

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