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Letters to Regulators

Letter To Regulators: Standardized Approach for Calculating the Exposure Amount of Derivatives Contracts
February 15, 2019 – 11:27 am

The replacement of the CEM by the SA-CCR would significantly reduce leverage capital requirements for bank derivatives positions, which we believe would cut total capital backing derivatives books at large banks.

Letter To Regulators: Comment On Standardized Approach For Calculating The Exposure Amount Of Derivatives Contracts
February 15, 2019 – 11:21 am

The replacement of the CEM by the SA-CCR would significantly reduce leverage capital requirements for bank derivatives positions, which we believe would cut total capital backing derivatives books at large banks.

Joint Letter: 9 groups oppose the CFPB’s proposed changes to its no-action letter policy and new sandbox proposal
February 12, 2019 – 12:13 pm

9 groups oppose the CFPB’s proposed changes to its no-action letter policy and new sandbox proposal

Joint Letter: 80 groups oppose CFPB’s no-action letter and sandbox proposal
February 12, 2019 – 11:41 am

Letter from 80 groups opposing the CFPB’s changes to its no-action letter policy and new sandbox proposal

Joint Letter: Letter urging the CFPB to oppose the banking agencies’ proposal to raise the appraisal exemption threshold
February 5, 2019 – 7:42 pm

Letter urging the CFPB to oppose the banking agencies’ proposal to raise the appraisal exemption threshold

Joint Letter: Letter to the OCC, FDIC, and Fed Opposing Proposal to Raise Appraisal Exemption Threshold
February 5, 2019 – 7:39 pm

Letter to the OCC, FDIC, and Fed opposing proposal to raise the appraisal exemption threshold

Joint Letter: Consumer Groups Urge FDIC To Promote Financial Inclusion For Distressed Consumers
January 24, 2019 – 12:48 pm

Several safeguards are critical to ensure that bank loan programs—particularly those designed for financially distressed consumers—promote financial inclusion rather than exacerbate financial exclusion and distress.