TSL Express Daily News

As noted late last year, SFNet’s Advocacy Committee assembled a task force including member banking institutions, legal resources and strategic advisors to address proposed new regulations incorporating Basel III risk weighted capital standards. SFNet has submitted its comment letter. Special thanks to Laura Jakubowski and Richard Kohn from Goldberg Kohn and Bill Mayer from Tiger Group for their leadership on this pivotal matter.

In the October announcement, SFNet CEO Rich Gumbrecht pointed out that the proposed rules are significantly flawed by not taking into account the value of inventory and receivables collateral, and structural controls in reducing loss given default in our product scope. If finalized in its current form, these omissions will lead to unnecessarily high capital charges, which will have a direct negative effect on borrowers and lenders far beyond large bank regulated institutions. SFNet’s comments address these concerns and urges the regulators to modify the proposed rules before they are finalized.

In advance of submitting our comments, SFNet held productive meetings with peer trade groups, such as the American Bankers Association (ABA) and the Securities Industry and Financial Markets Association (SIFMA), key congressional leaders, and the three regulatory agencies (OCC, Federal Reserve and FDIC) to educate policymakers and stakeholders about our concerns.  The comment period ends on January 16, after which the agencies will take time to deliberate. The regulatory agencies have invited us to keep the dialogue flowing after they have had time to digest the information submitted.  

We urge members to voice their support for SFNet’s comment letter by sending their own letter before the comment period ends on January 16.

See below for how to submit comments:

• Federal Reserve Board: You may submit comments, identified by Docket No. R–1813, RIN 7100–AG64 by any of the following methods:
• Email: regs.comments@federalreserve.gov. Include the docket number and RIN in the subject line of the message.
• FDIC: The FDIC encourages interested parties to submit written comments. Please include your name, affiliation, address, email address, and telephone number(s) in your comment. You may submit comments to the FDIC, identified by RIN 3064–AF29 by any of the following methods:
• Email: comments@FDIC.gov. Include the RIN 3064–AF29 on the subject line of the message.
• OCC: https://www.regulations.gov/commenton/OCC-2023-0008-0021

Instructions: You must include “OCC” as the agency name and “Docket ID OCC–2023–0008” in your comment. In general, the OCC will enter all comments received into the docket and publish the comments on the Regulations.gov website without change, including any business or personal information provided such as name and address information, email addresses, or phone numbers. Comments received, including attachments and other supporting materials, are part of the public record and subject to public disclosure. Do not include any information in your comment or supporting materials that you consider confidential or inappropriate for public.

We will keep our members apprised of our progress. In the meantime, please send any feedback or questions directly to Rich Gumbrecht at rgumbrecht@sfnet.com, or Lon Goldstein at lon@goldsteinpolicy.com.