The Committee on Capital Markets Regulation submitted a comment letter on the Proposed Rule released by the Board of Governors of the Federal Reserve System (the “Fed”) regarding total loss-absorbing capacity (“TLAC”) and related requirements for global systematically important banks (“G-SIBs”). The Committee supports the Fed’s stated goal of improving the resolvability and resiliency of G-SIBs and generally endorses the TLAC approach. In general, the Committee believes that the Fed should seek to conform its final rule to the international standard for TLAC issued by the Financial Stability Board (“FSB”).

Read the full comment letter here.