AFR’s Comment Letter on Risk Management Standards for Certain Financial Market Utilities
AFR commented on the Federal Reserve’s proposed rule setting out risk-management standards for systemically significant financial market utilities. Examples of such entities would include major derivatives clearinghouses, key bank payment systems, and repo clearing banks. AFR’s letter urged an increase capital requirements for such entities, more specific risk management standards, and a requirement that key risk assessments be performed by impartial third parties.