Joint Comment Letter to the Board re: LISCC Supervisory Program

Ann E. Misback, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Washington, DC 20551

Ladies and Gentlemen:

The Securities Industry and Financial Markets Association (“SIFMA”), the Institute of International Bankers (“IIB”), the Bank Policy Institute (“BPI”), and the American Bankers Association (“ABA”) appreciate the opportunity to comment on the draft SR Letter issued by the Board of Governors of the Federal Reserve System (the “Board”) defining the financial institutions subject to the Large Institution Supervision Coordinating Committee (“LISCC”) supervisory program as institutions subject to Category I standards under the Board’s tailoring framework, as well as the Board’s request for input on the appropriate criteria for including international banks in the LISCC program in the future should the risk of their U.S. operations increase.

We strongly support the Board’s decision to define the financial institutions subject to the LISCC program as any firm subject to Category I tailoring standards and recommend it continue to use this same applicability definition when it updates the draft SR Letter prior to March 31, 2021. We also outline additional applicability criteria that the Board could consider should the risk of any international bank’s U.S. operations significantly increase in the future.

Download the comment letter to read the full text.