JOHN DEARIE

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum encourages Congress to study the impact of the plan to reduce the rate on annual dividend payments that financial institutions receive on their shares in the Federal Reserve. The reduction in the dividend rate was used as an offset to the cost of reauthorizing the Highway Trust Fund. The Forum is of the view that Congress should ultimately find a more flexible solution that enables these companies to make more credit available to the real economy. The Forum supported the Reps. Neugebauer-Huizenga amendment to H.R. 22, the DRIVE Act, which would remove from H.R. 22 the harmful proposal to reduce the dividend paid on Federal Reserve stock that would have significant negative consequences on banks of all sizes across the country. The Forum supports H.R. 3738, The Office of Financial Research Accountability Act of 2015. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate an orderly resolution. The Forum joined other associations in writing a comment letter on the proposed TLAC rule to ensure that the details of the rule are appropriately calibrated to work effectively with the business models and capital structures of a variety of different large banking institutions. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum encourages Congress to study the impact of the plan to reduce the rate on annual dividend payments that financial institutions receive on their shares in the Federal Reserve. The reduction in the dividend rate was used as an offset to the cost of reauthorizing the Highway Trust Fund. The Forum is of the view that Congress should ultimately find a more flexible solution that enables these companies to make more credit available to the real economy. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate an orderly resolution. The Forum joined other associations in writing a comment letter on the proposed TLAC rule to ensure that the details of the rule are appropriately calibrated to work effectively with the business models and capital structures of a variety of different large banking institutions. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act.

Financial Regulation Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promote financial system stability, and protect depositors, consumers, and investors. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum opposes legislation to preemptively dismantle well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, or punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum supports international coordination on derivatives regulation, and believes U.S. regulators should harmonize policies to avoid confusion. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate orderly resolution. In mid-2016, the Forum joined other associations in writing a comment letter on the proposed TLAC rule to ensure that the details of the rule are appropriately calibrated to work effectively with the business models and capital structures of large banking institutions. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd-Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act. The Forum opposes the recommendation by the Federal Reserve, FDIC, and OCC that Congress should repeal the provisions of the Gramm-Leach-Bliley Act that permit merchant banking and related authorities. The Forum is of the view that the reasoning offered by the agencies for their recommendation is highly dubious and unpersuasive. Congress and regulators should conduct more robust analysis before moving forward. The Forum commends the House Financial Services Committee in addressing the important policy challenges of regulatory balance, ensuring financial stability, and ending too-big-to-fail. The Forum is supportive of a number of aspects of H.R.5983: The Financial CHOICE Act of 2016, including reducing unnecessary regulatory burden that undermines credit availability and economic growth, creating a credible and predictable bankruptcy regime for large financial institutions, and reassessing aspects of the Volcker Rule and debit card interchange fees. The CHOICE Acts focus on a 10 percent strict leverage ratio, however, risks overlooking the significant system-strengthening progress already made to date, as well as the reality that additional capital is not without costs or consequences.

Financial Regulation Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promote financial system stability, and protect depositors, consumers, and investors. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum opposes legislation to preemptively dismantle well-capitalized and well-managed financial institutions, or punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum supports international coordination on derivatives regulation, and believes U.S. regulators should harmonize policies to avoid confusion. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate orderly resolution. The TLAC rule ensures that all losses resulting from a failure of one of the largest financial institutions are borne by private creditors and shareholders, not the taxpayer. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd-Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act. The Forum opposes the recommendation by the Federal Reserve, FDIC, and OCC that Congress should repeal the provisions of the Gramm-Leach-Bliley Act that permit merchant banking and related authorities. The Forum is of the view that the reasoning offered by the agencies for their recommendation is highly dubious and unpersuasive. Congress and regulators should conduct more robust analysis before moving forward. The Forum is supportive of a number of aspects of H.R.5983: The Financial CHOICE Act of 2016, including reducing unnecessary regulatory burden that undermines credit availability and economic growth, creating a credible and predictable bankruptcy regime for large financial institutions, and reassessing aspects of the Volcker Rule and debit card interchange fees. The CHOICE Acts focus on a 10 percent strict leverage ratio, however, risks overlooking the significant system-strengthening progress already made to date, as well as the reality that additional capital is not without costs or consequences.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum encourages Congress to study the impact of the plan to reduce the rate on annual dividend payments that financial institutions receive on their shares in the Federal Reserve. The reduction in the dividend rate was used as an offset to the cost of reauthorizing the Highway Trust Fund. The Forum is of the view that Congress should ultimately find a more flexible solution that enables these companies to make more credit available to the real economy. The Forum supported the Reps. Neugebauer-Huizenga amendment to H.R. 22, the DRIVE Act, which would remove from H.R. 22 the harmful proposal to reduce the dividend paid on Federal Reserve stock that would have significant negative consequences on banks of all sizes across the country. The Forum supports H.R. 3738, The Office of Financial Research Accountability Act of 2015. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate an orderly resolution. The Forum joined other associations in writing a comment letter on the proposed TLAC rule to ensure that the details of the rule are appropriately calibrated to work effectively with the business models and capital structures of a variety of different large banking institutions. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category.

Financial Regulation Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promote financial system stability, and protect depositors, consumers, and investors. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum opposes legislation to preemptively dismantle well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, or punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum supports international coordination on derivatives regulation, and believes U.S. regulators should harmonize policies to avoid confusion. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate orderly resolution. In mid-2016, the Forum joined other associations in writing a comment letter on the proposed TLAC rule to ensure that the details of the rule are appropriately calibrated to work effectively with the business models and capital structures of large banking institutions. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd-Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act. The Forum opposes the recommendation by the Federal Reserve, FDIC, and OCC that Congress should repeal the provisions of the Gramm-Leach-Bliley Act that permit merchant banking and related authorities. The Forum is of the view that the reasoning offered by the agencies for their recommendation is highly dubious and unpersuasive. Congress and regulators should conduct more robust analysis before moving forward. The Forum commends the House Financial Services Committee in addressing the important policy challenges of regulatory balance, ensuring financial stability, and ending too-big-to-fail. The Forum is supportive of a number of aspects of H.R.5983: The Financial CHOICE Act of 2016, including reducing unnecessary regulatory burden that undermines credit availability and economic growth, creating a credible and predictable bankruptcy regime for large financial institutions, and reassessing aspects of the Volcker Rule and debit card interchange fees. The CHOICE Acts focus on a 10 percent strict leverage ratio, however, risks overlooking the significant system-strengthening progress already made to date, as well as the reality that additional capital is not without costs or consequences.

Financial Regulation Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promote financial system stability, and protect depositors, consumers, and investors. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum opposes legislation to preemptively dismantle well-capitalized and well-managed financial institutions, or punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum supports international coordination on derivatives regulation, and believes U.S. regulators should harmonize policies to avoid confusion. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate orderly resolution. The TLAC rule ensures that all losses resulting from a failure of one of the largest financial institutions are borne by private creditors and shareholders, not the taxpayer. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd-Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act. The Forum opposes the recommendation by the Federal Reserve, FDIC, and OCC that Congress should repeal the provisions of the Gramm-Leach-Bliley Act that permit merchant banking and related authorities. The Forum is of the view that the reasoning offered by the agencies for their recommendation is highly dubious and unpersuasive. Congress and regulators should conduct more robust analysis before moving forward. The Forum is supportive of a number of aspects of H.R.5983: The Financial CHOICE Act of 2016, including reducing unnecessary regulatory burden that undermines credit availability and economic growth, creating a credible and predictable bankruptcy regime for large financial institutions, and reassessing aspects of the Volcker Rule and debit card interchange fees. The CHOICE Acts focus on a 10 percent strict leverage ratio, however, risks overlooking the significant system-strengthening progress already made to date, as well as the reality that additional capital is not without costs or consequences.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum encourages Congress to study the impact of the plan to reduce the rate on annual dividend payments that financial institutions receive on their shares in the Federal Reserve. The reduction in the dividend rate was used as an offset to the cost of reauthorizing the Highway Trust Fund. The Forum is of the view that Congress should ultimately find a more flexible solution that enables these companies to make more credit available to the real economy. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate an orderly resolution. The Forum joined other associations in writing a comment letter on the proposed TLAC rule to ensure that the details of the rule are appropriately calibrated to work effectively with the business models and capital structures of a variety of different large banking institutions. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act.

Financial Regulation Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promote financial system stability, and protect depositors, consumers, and investors. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum opposes legislation to preemptively dismantle well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, or punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum supports international coordination on derivatives regulation, and believes U.S. regulators should harmonize policies to avoid confusion. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate orderly resolution. In mid-2016, the Forum joined other associations in writing a comment letter on the proposed TLAC rule to ensure that the details of the rule are appropriately calibrated to work effectively with the business models and capital structures of large banking institutions. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd-Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act. The Forum opposes the recommendation by the Federal Reserve, FDIC, and OCC that Congress should repeal the provisions of the Gramm-Leach-Bliley Act that permit merchant banking and related authorities. The Forum is of the view that the reasoning offered by the agencies for their recommendation is highly dubious and unpersuasive. Congress and regulators should conduct more robust analysis before moving forward. The Forum commends the House Financial Services Committee in addressing the important policy challenges of regulatory balance, ensuring financial stability, and ending too-big-to-fail. The Forum is supportive of a number of aspects of H.R.5983: The Financial CHOICE Act of 2016, including reducing unnecessary regulatory burden that undermines credit availability and economic growth, creating a credible and predictable bankruptcy regime for large financial institutions, and reassessing aspects of the Volcker Rule and debit card interchange fees. The CHOICE Acts focus on a 10 percent strict leverage ratio, however, risks overlooking the significant system-strengthening progress already made to date, as well as the reality that additional capital is not without costs or consequences.

Financial Regulation Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promote financial system stability, and protect depositors, consumers, and investors. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum opposes legislation to preemptively dismantle well-capitalized and well-managed financial institutions, or punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum supports international coordination on derivatives regulation, and believes U.S. regulators should harmonize policies to avoid confusion. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. The Forum generally supports efforts by the Federal Reserve to impose a total loss absorbing capacity (TLAC) requirement on the largest banking firms to make those firms more resilient and to facilitate orderly resolution. The TLAC rule ensures that all losses resulting from a failure of one of the largest financial institutions are borne by private creditors and shareholders, not the taxpayer. The Forum supports the Federal Reserve utilizing its statutory authority under the Dodd-Frank Act to extend the date for the required sale of banks positions in illiquid funds to 2022. This would conform actual practice with the final rule that governs permitted bank investments in this investment category. The Forum supports Congress reviewing options to enhance the U.S. Bankruptcy Code in order to facilitate the orderly resolution of a failed financial institution. While there are many possible ways to achieve this goal, the Forum would support enactment of H.R. 2947, The Financial Institution Bankruptcy Act of 2016, and S.1841, Taxpayer Protection and Responsible Resolution Act. The Forum opposes the recommendation by the Federal Reserve, FDIC, and OCC that Congress should repeal the provisions of the Gramm-Leach-Bliley Act that permit merchant banking and related authorities. The Forum is of the view that the reasoning offered by the agencies for their recommendation is highly dubious and unpersuasive. Congress and regulators should conduct more robust analysis before moving forward. The Forum is supportive of a number of aspects of H.R.5983: The Financial CHOICE Act of 2016, including reducing unnecessary regulatory burden that undermines credit availability and economic growth, creating a credible and predictable bankruptcy regime for large financial institutions, and reassessing aspects of the Volcker Rule and debit card interchange fees. The CHOICE Acts focus on a 10 percent strict leverage ratio, however, risks overlooking the significant system-strengthening progress already made to date, as well as the reality that additional capital is not without costs or consequences.

Cyber security: Cyber-crime and cyber-terrorism are mounting threats to U.S. business interests in the digital age. The Forum is of the view that the ability of businesses to actively cooperate by sharing information regarding the nature, origin, and severity of incoming threats is critical to defending commercial interests and the security of customer information. Businesses and corporations must have the information and technical tools necessary to collaborate with the public sector to address cyber risks. The Forum is supportive of H.R.1560, Protecting Cyber Networks Act and urges passage of the Senate companion bill, S.754, Cybersecurity Information Sharing Act of 2015

Cyber security: Cyber-crime and cyber-terrorism are mounting threats to U.S. business interests in the digital age. The Forum is of the view that the ability of businesses to actively cooperate by sharing information regarding the nature, origin, and severity of incoming threats is critical to defending commercial interests and the security of customer information. Businesses and corporations must have the information and technical tools necessary to collaborate with the public sector to address cyber risks. The Forum is supportive of H.R.1560, Protecting Cyber Networks Act and urges passage of the Senate companion bill, S.754, Cybersecurity Information Sharing Act of 2015

Cyber security: Cyber-crime and cyber-terrorism are mounting threats to U.S. business interests in the digital age. The Forum is of the view that the ability of businesses to actively cooperate by sharing information regarding the nature, origin, and severity of incoming threats is critical to defending commercial interests and the security of customer information. Businesses and corporations must have the information and technical tools necessary to collaborate with the public sector to address cyber risks. The Forum is supportive of H.R.1560, Protecting Cyber Networks Act and urges passage of the Senate companion bill, S.754, Cybersecurity Information Sharing Act of 2015

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum encourages Congress to study the impact of the plan to reduce the rate on annual dividend payments that financial institutions receive on their shares in the Federal Reserve. The reduction in the dividend rate was used as an offset to the cost of reauthorizing the Highway Trust Fund. The Forum is of the view that Congress should ultimately find a more flexible solution that enables these companies to make more credit available to the real economy. The Forum supported the Reps. Neugebauer-Huizenga amendment to H.R. 22, the DRIVE Act, which would remove from H.R. 22 the harmful proposal to reduce the dividend paid on Federal Reserve stock that would have significant negative consequences on banks of all sizes across the country. The Forum supports H.R. 3738, The Office of Financial Research Accountability Act of 2015.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum encourages Congress to study the impact of the plan to reduce the rate on annual dividend payments that financial institutions receive on their shares in the Federal Reserve. The reduction in the dividend rate was used as an offset to the cost of reauthorizing the Highway Trust Fund. The Forum is of the view that Congress should ultimately find a more flexible solution that enables these companies to make more credit available to the real economy. The Forum supported the Reps. Neugebauer-Huizenga amendment to H.R. 22, the DRIVE Act, which would remove from H.R. 22 the harmful proposal to reduce the dividend paid on Federal Reserve stock that would have significant negative consequences on banks of all sizes across the country. The Forum supports H.R. 3738, The Office of Financial Research Accountability Act of 2015.

The Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and supporting policies that provide access to capital and credit for new and small businesses. The Forum is supportive of S. 181: The Startup Act, a bipartisan jobs plan aimed at jumpstarting the economy through the creation and growth of new businesses.

The Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and supporting policies that provide access to capital and credit for new and small businesses. The Forum is supportive of S. 181: The Startup Act, a bipartisan jobs plan aimed at jumpstarting the economy through the creation and growth of new businesses.

Cyber security: Cyber-crime and cyber-terrorism are mounting threats to U.S. business interests in the digital age. The Forum is of the view that the ability of businesses to actively cooperate by sharing information regarding the nature, origin, and severity of incoming threats is critical to defending commercial interests and the security of customer information. Businesses and corporations must have the information and technical tools necessary to collaborate with the public sector to address cyber risks. The Forum is supportive of H.R.1560, Protecting Cyber Networks Act and urges passage of the Senate companion bill, S.754, Cybersecurity Information Sharing Act of 2015

Cyber security: Cyber-crime and cyber-terrorism are mounting threats to U.S. business interests in the digital age. The Forum is of the view that the ability of businesses to actively cooperate by sharing information regarding the nature, origin, and severity of incoming threats is critical to defending commercial interests and the security of customer information. Businesses and corporations must have the information and technical tools necessary to collaborate with the public sector to address cyber risks. The Forum is supportive of H.R.1560, Protecting Cyber Networks Act and urges passage of the Senate companion bill, S.754, Cybersecurity Information Sharing Act of 2015

Cyber security: Cyber-crime and cyber-terrorism are mounting threats to U.S. business interests in the digital age. The Forum is of the view that the ability of businesses to actively cooperate by sharing information regarding the nature, origin, and severity of incoming threats is critical to defending commercial interests and the security of customer information. Businesses and corporations must have the information and technical tools necessary to collaborate with the public sector to address cyber risks. The Forum is supportive of H.R.1560, Protecting Cyber Networks Act and urges passage of the Senate companion bill, S.754, Cybersecurity Information Sharing Act of 2015

The Forum is strongly of the view that Congress should work together to ensure the U.S. is able to meet all its financial obligations on time to ensure global confidence in our markets, currency, and political process. The Forum supports tackling comprehensive tax reform and the development of a long-term plan to address America's national debt, particularly entitlement spending. The Forum actively engaged on provisions of the House and Senate Budget Resolutions, relating to the Dodd-Frank Act, that impacted our members including: S. Con. Res 11 Amendment No. 994.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports.The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced at the latest round of the U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economyespecially in the financial services sectorit would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports financial services inclusion in TTIP. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports. The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced during the 2013 U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economy-especially in the financial services sector-it would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports financial services inclusion in TTIP. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports.The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced at the latest round of the U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economyespecially in the financial services sectorit would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports financial services inclusion in TTIP. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports.The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum regards policies intended to penalize or punish China as counterproductive. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced at the latest round of the U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economyespecially in the financial services sectorit would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports financial services inclusion in TTIP. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the saftey and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investorsThe "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014 and S.1861: The Taxpayer Protection and Responsible Resolution Act. The Forum supports H.R.5461: To clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the saftey and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investorsThe "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014 and S.1861: The Taxpayer Protection and Responsible Resolution Act. The Forum supports H.R.5461: To clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports.The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced at the latest round of the U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economyespecially in the financial services sectorit would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports financial services inclusion in TTIP. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports. The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced during the 2013 U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economy-especially in the financial services sector-it would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports financial services inclusion in TTIP. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports.The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced at the latest round of the U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economyespecially in the financial services sectorit would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports financial services inclusion in TTIP. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports.The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum regards policies intended to penalize or punish China as counterproductive. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced at the latest round of the U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economyespecially in the financial services sectorit would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports financial services inclusion in TTIP. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, FED and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. Complementary Activities, Merchant Banking Activities, and Other Activities of Financial Holding Companies Related to Physical Commodities, Docket No. R-1479; RIN 7100 AE-10 - The Forum believes that allowing financial holding companies to continue to conduct physical commodities activities, all while applying the right safeguards, is an important aspect of ensuring the global competitiveness and openness of our American markets.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the saftey and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investorsThe "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home.The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, FED and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014 and S.1861: The Taxpayer Protection and Responsible Resolution Act. The Forum supports H.R.5461: To clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014 and S.1861: The Taxpayer Protection and Responsible Resolution Act. The Forum supports H.R.5461: To clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home.The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, FED and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, FED and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. Complementary Activities, Merchant Banking Activities, and Other Activities of Financial Holding Companies Related to Physical Commodities, Docket No. R-1479; RIN 7100 AE-10 - The Forum believes that allowing financial holding companies to continue to conduct physical commodities activities, all while applying the right safeguards, is an important aspect of ensuring the global competitiveness and openness of our American markets.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the saftey and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investorsThe "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014 and S.1861: The Taxpayer Protection and Responsible Resolution Act. The Forum supports H.R.5461: To clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, FED and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. Complementary Activities, Merchant Banking Activities, and Other Activities of Financial Holding Companies Related to Physical Commodities, Docket No. R-1479; RIN 7100 AE-10 - The Forum believes that allowing financial holding companies to continue to conduct physical commodities activities, all while applying the right safeguards, is an important aspect of ensuring the global competitiveness and openness of our American markets.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the saftey and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investorsThe "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. The Forum is also of the view that any cost of funding advantage enjoyed by large diversified banking companies is not associated with an expectation on the part of market participants regarding future bailouts, but rather is due to the market-recognized benefits of institutional size, diversification of activities and income streams, and the stability and predictability of large institution earnings.Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home.The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, FED and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure.

Financial Regulatory Reform and Modernization - The Forum supports policies that ensure the safety and soundness of financial institutions, promotes financial system stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach - capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services - both of which contribute directly and importantly to economic growth and job creation here at home. The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, Federal Reserve and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure. The Forum is supportive of H.R. 5461: to clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes. H.R. 5461 includes important technical corrections to the Dodd-Frank Act that will strengthen the Act and provide critical clarifications to better oversee our financial system while allowing for economic growth. The Forum remains neutral but is following the progress of H.R. 5421: The Financial Institution Bankruptcy Act of 2014 and S.1861: The Taxpayer Protection and Responsible Resolution Act. The Forum supports H.R.5461: To clarify the application of certain leverage and risk-based requirements under the Dodd-Frank Wall Street Reform and Consumer Protection Act, to improve upon the definitions provided for points and fees in connection with a mortgage transaction, and for other purposes.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home.The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis. Liquidity Coverage Ratio -- Consistent with its promotion of policies that promote infrastructure investment and economic growth, the Forum is concerned that the current liquidity coverage ratio (LCR) that has been jointly proposed by the OCC, FED and the FDIC, will increase costs and decrease liquidity for municipal bond issuers, driving up the cost of needed investments in public schools, roads, and other critical infrastructure.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports.The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum regards policies intended to penalize or punish China as counterproductive. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced at the latest round of the U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economyespecially in the financial services sectorit would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports.The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum regards policies intended to penalize or punish China as counterproductive. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced at the latest round of the U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economyespecially in the financial services sectorit would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports.The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum regards policies intended to penalize or punish China as counterproductive. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced at the latest round of the U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economyespecially in the financial services sectorit would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

China - The Forum supports economic engagement with China to promote the liberalization of China's financial markets. Economic Engagement, Trade and Exports - The Forum supports promoting economic growth through international engagement, trade and exports.The Forum supports China's continued liberalization of its currency policy and accelerated movement toward a market-determined value of the yuan. The Forum regards policies intended to penalize or punish China as counterproductive. The Forum also urges faster and more comprehensive reform and modernization of China's financial system. A more modern and effective financial system is critically important to achieving China's goal of a more consumption-based Chinese economy -- which is very much in the interest of the United States. According to the Commerce Department, every additional $1 billion in exports creates approximately 5,000 new American jobs. The Forum is very supportive of a U.S.-China Bilateral Investment Treaty that was announced at the latest round of the U.S.-China Strategic and Economic Dialogue. If the two countries are able to reach an agreement for the U.S. to gain market access to Chinas economyespecially in the financial services sectorit would be a win-win for both countries, businesses and workers, as well as increase prospects for job creation and economic growth. The Forum is very supportive of the U.S.-EU Transatlantic Trade and Investment Partnership (TTIP), announced by President Obama during the 2013 State of the Union address. If achieved, the agreement would be the most ambitious since the founding of the WTO--encompassing 28 nations, half of global input, and a third of all trade. The Forum supports H.R. 2052 and S.1023: the Global Investment in American Jobs Act of 2013, which is aimed at improving Americas ability to attract job-creating foreign direct investment (FDI) from businesses around the world.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forumbelieves that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home.The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forumbelieves that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly toeconomic growth and job creation here at home.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home.The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forumbelieves that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly toeconomic growth and job creation here at home.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home.The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home.The Forum believes that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. Expected legislation regarding the permitted size and resolution of large financial institutions.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly toeconomic growth and job creation here at home.

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors.The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum supports international coordination on derivatives regulations, and believes U.S. regulators should harmonize their views internally, and avoid confusion. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. GAO Study -- S. 3709, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes. Value of large financial institutions -- The Forum opposes S.798, "Terminating Bailouts for Taypayer Fairness Act of 2013 or TBTF Act" and S.685, "Too Big to Fail, Too Big to Exist Act," S.1282 "The 21st Century Glass-Steagall Act of 2013," and other legislative efforts to forcibly break up large diversified banking companies. The Forum is strongly of the view that an economy of the scale and complexity of the U.S. economy needs financial institutions of all kinds to meet a wide variety of financial needs. Each charter type, business model, and institution size helps to best serve the unique financial needs of particular businesses, households, consumers, savers, and investors. Community and regional banks provide essential support to a wide range of businesses and households within their communities. Similarly, large diversified institutions provide value particularly important to large, globally active U.S. corporations, and to the further development of foreign markets for U.S. goods and services both of which contribute directly and importantly to economic growth and job creation here at home. The Forumbelieves that the "21st Century Glass-Steagall Act" would make the financial system more risky for the taxpayer by reintroducing the standalone broker-dealer model that proved unstable and by making the mergers of large firms impossible in a future crisis.

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration H.R. 3606: The Jumpstart Our Business Startups (JOBS) Act, S. 3217: Startup Act 2.0, H.R. 5893 Startup Act 2.0

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration H.R. 3606: The Jumpstart Our Business Startups (JOBS) Act, S. 3217: Startup Act 2.0, H.R. 5893 Startup Act 2.0

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration H.R. 3606: The Jumpstart Our Business Startups (JOBS) Act, S. 3217: Startup Act 2.0, H.R. 5893 Startup Act 2.0

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration H.R. 3606: The Jumpstart Our Business Startups (JOBS) Act, S. 3217: Startup Act 2.0, H.R. 5893 Startup Act 2.0

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration

S. 365, "Budget Control Act of 2011", The Forum feels strongly that Congress should work together to enable the U.S. to be able to meet all its financial obligations on time to ensure global confidence in our markets, currency, and political process. The Forum believes the downsides of U.S. default could cause undesirable ripple effects to the global economy. The Forum supported H.R. 3010, the Regulatory Accountability Act of 2011, would modernize and update the 65-year old regulatory process, and improve how federal agencies promulgate regulations with the most significant affects on jobs and economic growth.

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration H.R. 3606: The Jumpstart Our Business Startups (JOBS) Act, S. 3217: Startup Act 2.0, H.R. 5893 Startup Act 2.0

Financial Regulatory Reform and Modernization - The Forum supports reform and modernization of the financial regulatory system to ensure the safety and soundness of financial institutions, promote financial systemic stability, and protect the varied interests of depositors, consumers, and investors. The "Wall Street Reform and Consumer Protection Act" - The Forum supports financial regulatory reform that: 1) establishes resolution authority to end "too-big-to-fail"; 2) enhances consumer protections; 3) regulates over-the-counter derivatives; and, 4) provides for "systemic supervision" of the U.S. financial system. The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, haircuts on secured creditors to financial institutions in the course of a resolution, and punitive taxes or levies on financial institutions. The U.S. economy, the world's largest and most diverse, needs financial institutions of all sizes and business models. Smaller institutions effectively serve the needs of certain aspects of our economy, while larger institutions serve the needs of other aspects. The unique value of large institutions includes the sheer size of credits they can deliver, the array of products and services they offer, and their geographic reach capacities that smaller institutions simply dont share. Such size and scope-related capabilities are particularly important to globally active corporations and contribute directly to economic growth and job creation. Large banks, active in many countries across the world, also help integrate global stock, bond, and foreign exchange markets, making those markets more modern, liquid, and efficient. And large, globally active banks expand the supply of credit and other financial services to emerging market economies, making important contributions to the expansion of trade flows and opening foreign markets to U.S. goods and services. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum maintains that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. The Forum is actively engaged with the various financial regulators to ensure the effective implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010. The Forum is concerned with the proposed rules, specifically, among other areas, the extraordinary overstatement of exposures in the single-counterparty credit limits. Capital Requirements -- The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. The Forum is actively engaged with financial regulators to ensure the effective implementation of the Basel III capital and liquidity framework. Capital Market Competitiveness -- The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy. Volcker Rule -- The Forum supports H.R. 6524, the "U.S. Financial Services Global Viability Act." H.R. 6524 would suspend enforcement of the Volcker Rule at least until other countries adopt similar statutory restrictions. GAO Study -- S. 3708, To require a Government Accountability Office examination of transactions between large financial institutions and the Federal Government, and for other purposes.

Tax Policy - The Forum supports tax policy that keeps the U.S. economy open to create jobs, and attract foreign investment. The Forum believes that imposing taxes and fees on the financial sector will restrict the availability of credit, increase the tax burden on investors and impede the ability of the financial sector to create jobs. S. 722, the "Taxpayer Certainty and Relief Act" - The Forum supports strengthening the economy through policies that foster private savings and capital investment. The Forum supports maintaining the existing tax rates on dividends and capital gains. The Forum opposes onerous fees and taxes imposed on large financial institutions that will undermine economic growth by impairing the ability of financial institutions to extend credit to individuals and businesses.

Tax Policy - The Forum supports tax policy that keeps the U.S. economy open to create jobs, and attract foreign investment. The Forum believes that imposing taxes and fees on the financial sector will restrict the availability of credit, increase the tax burden on investors and impede the ability of the financial sector to create jobs. S. 722, the "Taxpayer Certainty and Relief Act" - The Forum supports strengthening the economy through policies that foster private savings and capital investment. The Forum supports maintaining the existing tax rates on dividends and capital gains. The Forum opposes onerous fees and taxes imposed on large financial institutions that will undermine economic growth by impairing the ability of financial institutions to extend credit to individuals and businesses.

Tax Policy - The Forum supports tax policy that keeps the U.S. economy open to create jobs, and attract foreign investment. The Forum believes that imposing taxes and fees on the financial sector will restrict the availability of credit, increase the tax burden on investors and impede the ability of the financial sector to create jobs. S. 722, the "Taxpayer Certainty and Relief Act" - The Forum supports strengthening the economy through policies that foster private savings and capital investment. The Forum supports maintaining the existing tax rates on dividends and capital gains. India Finance Bill 2012 - The Forum opposes proposed tax amendments in the India Finance Bill 2012. These proposed amendments will have a significant negative effect on our companies, customers and shareholders, and investors in India and may have a detrimental impact on the flow of direct investment into India. The Forum opposes onerous fees and taxes imposed on large financial institutions that will undermine economic growth by impairing the ability of financial institutions to extend credit to individuals and businesses.

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration H.R. 3606: The Jumpstart Our Business Startups (JOBS) Act, S. 3217: Startup Act 2.0, H.R. 5893 Startup Act 2.0

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration

The Financial Services Forum supports policies that enhance the circumstances for new business formation and survival by reducing regulatory burden and policies that provide access to capital and credit for new and small businesses. S. 1835 United States Covered Bond Act of 2011, S. 1831 The Access to Capital Job Creators Act, S. 1791 The Democratizing Access to Capital Act, S. 1824 The Private Company Flexibility and Growth Act H.R. 2930 Entrepreneur Access to Capital Act, H.R. 2940 Access to Capital for Job Creators Act, H.R. 2167 Private Company Flexibility and Growth Act, H.R. 1965 To amend the securities laws to establish certain thresholds for shareholder registration

S. 365, "Budget Control Act of 2011", The Forum feels strongly that Congress should work together to enable the U.S. to be able to meet all its financial obligations on time to ensure global confidence in our markets, currency, and political process. The Forum believes the downsides of U.S. default could cause undesirable ripple effects to the global economy. The Forum supported H.R. 3010, the Regulatory Accountability Act of 2011, would modernize and update the 65-year old regulatory process, and improve how federal agencies promulgate regulations with the most significant affects on jobs and economic growth.

Tax Policy - The Forum supports tax policy that keeps the U.S. economy open to create jobs, and attract foreign investment. The Forum believes that imposing taxes and fees on the financial sector will restrict the availability of credit, increase the tax burden on investors and impede the ability of the financial sector to create jobs. S. 722, the "Taxpayer Certainty and Relief Act" - The Forum supports strengthening the economy through policies that foster private savings and capital investment. The Forum supports maintaining the existing tax rates on dividends and capital gains. The Forum opposes onerous fees and taxes imposed on large financial institutions that will undermine economic growth by impairing the ability of financial institutions to extend credit to individuals and businesses.

Tax Policy - The Forum supports tax policy that keeps the U.S. economy open to create jobs, and attract foreign investment. The Forum believes that imposing taxes and fees on the financial sector will restrict the availability of credit, increase the tax burden on investors and impede the ability of the financial sector to create jobs. S. 722, the "Taxpayer Certainty and Relief Act" - The Forum supports strengthening the economy through policies that foster private savings and capital investment. The Forum supports maintaining the existing tax rates on dividends and capital gains. The Forum opposes onerous fees and taxes imposed on large financial institutions that will undermine economic growth by impairing the ability of financial institutions to extend credit to individuals and businesses.

Tax Policy - The Forum supports tax policy that keeps the U.S. economy open to create jobs, and attract foreign investment. The Forum believes that imposing taxes and fees on the financial sector will restrict the availability of credit, increase the tax burden on investors and impede the ability of the financial sector to create jobs. S. 722, the "Taxpayer Certainty and Relief Act" - The Forum supports strengthening the economy through policies that foster private savings and capital investment. The Forum supports maintaining the existing tax rates on dividends and capital gains. The Forum opposes onerous fees and taxes imposed on large financial institutions that will undermine economic growth by impairing the ability of financial institutions to extend credit to individuals and businesses.

Tax Policy - The Forum supports tax policy that keeps the U.S. economy open to create jobs, and attract foreign investment. The Forum believes that imposing taxes and fees on the financial sector will restrict the availability of credit, increase the tax burden on investors and impede the ability of the financial sector to create jobs. S. 722, the "Taxpayer Certainty and Relief Act" - The Forum supports strengthening the economy through policies that foster private savings and capital investment. The Forum supports maintaining the existing tax rates on dividends and capital gains. The Forum opposes onerous fees and taxes imposed on large financial institutions that will undermine economic growth by impairing the ability of financial institutions to extend credit to individuals and businesses.

Tax Policy - The Forum supports tax policy that keeps the U.S. economy open to create jobs, and attract foreign investment. H.R. 1068 to impose a tax on securities transactions - Legislation to impose a securities tax would restrict the availability of credit, increase the tax burden on investors and impede the ability of the financial sector to create jobs. S. 2994, to impose an excise tax on 2009 bonuses from certain major recipients of Federal emergency economic assistance, to limit the deductible allowances for such bonuses. The Forum opposes onerous fees and taxes imposed on large financial institutions that will undermine economic growth by impairing the ability of financial institutions to extend credit to individuals and businesses. S. 722, "The Taxpayer Certainty and Relief Act" - The Forum supports strengthening the economy through policies that foster private savings and capital investment. The Forum supports maintaining the existing tax rates on dividends and capital gains. H.R. 1944, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. The Forum supports making permanent in law the active financing rule governing how the U.S. taxes income earned by U.S. financial companies in foreign markets. The Forum supports corporate tax policies that allow for a temporary deferral of U.S. taxes until those earnings have been paid to the parent company.

Tax Policy - The Forum supports tax policy that keeps the U.S. economy open to create jobs, and attract foreign investment. H.R. 1068 to impose a tax on securities transactions - Legislation to impose a securities tax would restrict the availability of credit, increase the tax burden on investors and impede the ability of the financial sector to create jobs. S. 2994, to impose an excise tax on 2009 bonuses from certain major recipients of Federal emergency economic assistance, to limit the deductible allowances for such bonuses. The Forum opposes onerous fees and taxes imposed on large financial institutions that will undermine economic growth by impairing the ability of financial institutions to extend credit to individuals and businesses. S. 722, "The Taxpayer Certainty and Relief Act" - The Forum supports strengthening the economy through policies that foster private savings and capital investment. The Forum supports maintaining the existing tax rates on dividends and capital gains. H.R. 1944, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. The Forum supports making permanent in law the active financing rule governing how the U.S. taxes income earned by U.S. financial companies in foreign markets. The Forum supports corporate tax policies that allow for a temporary deferral of U.S. taxes until those earnings have been paid to the parent company.

Tax Policy - The Forum supports tax policy that keeps the U.S. economy open to create jobs, and attract foreign investment. The Forum believes that imposing taxes and fees on the financial sector will restrict the availability of credit, increase the tax burden on investors and impede the ability of the financial sector to create jobs. S. 722, the "Taxpayer Certainty and Relief Act" - The Forum supports strengthening the economy through policies that foster private savings and capital investment. The Forum supports maintaining the existing tax rates on dividends and capital gains. S. 2994, to impose an excise tax on 2009 bonuses from certain major recipients of Federal emergency economic assistance, to limit the deductible allowances for such bonuses. The Forum opposes onerous fees and taxes imposed on large financial institutions that will undermine economic growth by impairing the ability of financial institutions to extend credit to individuals and businesses. H.R. 1944, to amend the Internal Revenue Code of 1986 to permanently extend the subpart F exemption for active financing income. The Forum supports making permanent in law the active financing rule governing how the U.S. taxes income earned by U.S. financial companies in foreign markets. The Forum supports corporate tax policies that allow for a temporary deferral of U.S. taxes until those earnings have been paid to the parent company.

Financial Regulatory Reform and Modernization - The Forum supports modernization and reform of the financial regulatory system to ensure the safety and soundness of financial institutions, the stability of the U.S. financial system and the protection of the varied interests of depositors, consumers, and investors. H.R. 4173, "the Wall Street Reform and Consumer Protection Act" and S. 3217, "the Restoring American Financial Stability Act" (Committee Print) - The Forum supports financial regulatory reform that would: 1) establish resolution authority to end "too-big-to-fail", 2) enhance consumer protections; 3) regulate over-the-counter derivatives; and, 4) designate a "systemic supervisor." The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, believes that imposing haircuts on secured creditors to financial institutions in resolution would introduce systemic risk into the financial system, supports maintaining the establishment of uniform national banking to ensure an efficient banking system, opposes calculating risk based deposit assessments on an insured depository's total assets rather than total domestic deposits, supports retaining supervisory authority of the Federal Reserve and supports post-funding of a new systemic risk resolution fund. The Forum supports risk retention requirements for mortgage originators and securitizers and establishing a new Office of Insurance within the Treasury Department. The Forum supports enhancement of consumer protection and believes that it should be a part of the policy response to the financial crisis. The Forum supports working with policy makers to ensure that consumers, depositors, investors, and policyholders enjoy the world's most steadfast and effective protection of their interests. The Forum supports executive compensation policies that reward attention to risk management and aligns incentives with the long-term viability and safety and soundness of financial institutions. H.R. 4375 & S. 2886, "the Glass-Steagall Restoration Act" - The Forum supports retaining a provision in "the Gramm-Leach-Bliley Act" that allows for the creation of financial holding companies (FHC) in which the FHC serves as an umbrella corporation for other financial subsidiaries. The Glass-Stegall Restoration Act would repeal this provision. The financial holding company structure structure did not contribute to the financial crisis. The Forum believes the appropriate policy response is enhanced supervision to minimize financial instability, coupled with resolution authority to end "too-big-to-fail." H.R. 3795, the Over the Counter Derivatives Markets Act, H.R. 2454, "the American Clean Energy and Security Act," H.R. 2448 "the Prevent Unfair Manipulation of Prices Act," H.R. 977, "the Derivatives Markets Transparency and Accountability Act" - Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum believes that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. APEC Privacy Framework - The Forum supports an APEC Privacy Framework that does not unduly restrict the global flow of data which is vital for financial institutions to meet customer needs and serve them efficiently. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness and systemic stability while not undermining lending that stimulates economic growth and job creation. Capital Market Competitiveness generally - The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy.

Financial Regulatory Reform and Modernization - The Forum supports modernization and reform of the financial regulatory system to ensure the safety and soundness of financial institutions, the stability of the U.S. financial system and the protection of the varied interests of depositors, consumers, and investors. H.R. 4173, "the Wall Street Reform and Consumer Protection Act" and S. 3217, "the Restoring American Financial Stability Act" (Committee Print) - The Forum supports financial regulatory reform that would: 1) establish resolution authority to end "too-big-to-fail", 2) enhance consumer protections; 3) regulate over-the-counter derivatives; and, 4) designate a "systemic supervisor." The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, believes that imposing haircuts on secured creditors to financial institutions in resolution would introduce systemic risk into the financial system, supports maintaining the establishment of uniform national banking to ensure an efficient banking system, opposes calculating risk based deposit assessments on an insured depository's total assets rather than total domestic deposits, supports retaining supervisory authority of the Federal Reserve and supports post-funding of a new systemic risk resolution fund. The Forum supports risk retention requirements for mortgage originators and securitizers and establishing a new Office of Insurance within the Treasury Department. The Forum supports enhancement of consumer protection and believes that it should be a part of the policy response to the financial crisis. The Forum supports working with policy makers to ensure that consumers, depositors, investors, and policyholders enjoy the world's most steadfast and effective protection of their interests. The Forum supports executive compensation policies that reward attention to risk management and aligns incentives with the long-term viability and safety and soundness of financial institutions. H.R. 4375 & S. 2886, "the Glass-Steagall Restoration Act" - The Forum supports retaining a provision in "the Gramm-Leach-Bliley Act" that allows for the creation of financial holding companies (FHC) in which the FHC serves as an umbrella corporation for other financial subsidiaries. The Glass-Stegall Restoration Act would repeal this provision. The financial holding company structure structure did not contribute to the financial crisis. The Forum believes the appropriate policy response is enhanced supervision to minimize financial instability, coupled with resolution authority to end "too-big-to-fail." H.R. 3795, the Over the Counter Derivatives Markets Act, H.R. 2454, "the American Clean Energy and Security Act," H.R. 2448 "the Prevent Unfair Manipulation of Prices Act," H.R. 977, "the Derivatives Markets Transparency and Accountability Act" - Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum believes that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. APEC Privacy Framework - The Forum supports an APEC Privacy Framework that does not unduly restrict the global flow of data which is vital for financial institutions to meet customer needs and serve them efficiently. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness and systemic stability while not undermining lending that stimulates economic growth and job creation. Capital Market Competitiveness generally - The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy.

Financial Regulatory Reform and Modernization - The Forum supports modernization and reform of the financial regulatory system to ensure the safety and soundness of financial institutions, the stability of the U.S. financial system and the protection of the varied interests of depositors, consumers, and investors. H.R. 4173, the "Wall Street Reform and Consumer Protection Act" and S. 3217, the "Restoring American Financial Stability Act" (Conference Report) - The Forum supports financial regulatory reform that would: 1) establish resolution authority to end "too-big-to-fail", 2) enhance consumer protections, 3) regulate over-the-counter derivatives; and, 4) designate a "systemic supervisor." The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, believes that imposing haircuts on secured creditors to financial institutions in resolution would introduce systemic risk into the financial system, supports maintaining the establishment of uniform national banking to ensure an efficient banking system, supports retaining supervisory authority of the Federal Reserve and supports post-funding of a new systemic risk resolution fund. The Forum supports risk retention requirements for mortgage originators and securitizers and establishing a new Office of Insurance within the Treasury Department. The Forum supports enhancement of consumer protection. The Forum supports working with policy makers to ensure that consumers, depositors, investors, and policyholders enjoy the world's most steadfast and effective protection of their interests. The Forum supports executive compensation policies that reward attention to risk management and aligns incentives with the long-term viability and safety and soundness of financial institutions. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum believes that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. H.R. 4375 & S. 2886, the "Glass-Steagall Restoration Act" - The Forum supports retaining a provision in the "Gramm-Leach-Bliley Act" that allows for the creation of financial holding companies (FHC) in which the FHC serves as an umbrella corporation for other financial subsidiaries. The Glass-Steagall Restoration Act would repeal this provision. The financial holding company structure did not contribute to the financial crisis. The Forum believes the appropriate policy response is enhanced supervision to minimize financial instability, coupled with resolution authority to end "too-big-to-fail." APEC Privacy Framework - The Forum supports an APEC Privacy Framework that does not unduly restrict the global flow of data which is vital for financial institutions to meet customer needs and serve them efficiently. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. Capital Market Competitiveness generally - The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy.

Financial Regulatory Reform and Modernization - The Forum supports modernization and reform of the financial regulatory system to ensure the safety and soundness of financial institutions, the stability of the U.S. financial system and the protection of the varied interests of depositors, consumers, and investors. H.R. 4173, "the Wall Street Reform and Consumer Protection Act" and S. 3217, "the Restoring American Financial Stability Act" (Committee Print) - The Forum supports financial regulatory reform that would: 1) establish resolution authority to end "too-big-to-fail", 2) enhance consumer protections; 3) regulate over-the-counter derivatives; and, 4) designate a "systemic supervisor." The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, believes that imposing haircuts on secured creditors to financial institutions in resolution would introduce systemic risk into the financial system, supports maintaining the establishment of uniform national banking to ensure an efficient banking system, opposes calculating risk based deposit assessments on an insured depository's total assets rather than total domestic deposits, supports retaining supervisory authority of the Federal Reserve and supports post-funding of a new systemic risk resolution fund. The Forum supports risk retention requirements for mortgage originators and securitizers and establishing a new Office of Insurance within the Treasury Department. The Forum supports enhancement of consumer protection and believes that it should be a part of the policy response to the financial crisis. The Forum supports working with policy makers to ensure that consumers, depositors, investors, and policyholders enjoy the world's most steadfast and effective protection of their interests. The Forum supports executive compensation policies that reward attention to risk management and aligns incentives with the long-term viability and safety and soundness of financial institutions. H.R. 4375 & S. 2886, "the Glass-Steagall Restoration Act" - The Forum supports retaining a provision in "the Gramm-Leach-Bliley Act" that allows for the creation of financial holding companies (FHC) in which the FHC serves as an umbrella corporation for other financial subsidiaries. The Glass-Stegall Restoration Act would repeal this provision. The financial holding company structure structure did not contribute to the financial crisis. The Forum believes the appropriate policy response is enhanced supervision to minimize financial instability, coupled with resolution authority to end "too-big-to-fail." H.R. 3795, the Over the Counter Derivatives Markets Act, H.R. 2454, "the American Clean Energy and Security Act," H.R. 2448 "the Prevent Unfair Manipulation of Prices Act," H.R. 977, "the Derivatives Markets Transparency and Accountability Act" - Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum believes that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. APEC Privacy Framework - The Forum supports an APEC Privacy Framework that does not unduly restrict the global flow of data which is vital for financial institutions to meet customer needs and serve them efficiently. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness and systemic stability while not undermining lending that stimulates economic growth and job creation. Capital Market Competitiveness generally - The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy.

Financial Regulatory Reform and Modernization - The Forum supports modernization and reform of the financial regulatory system to ensure the safety and soundness of financial institutions, the stability of the U.S. financial system and the protection of the varied interests of depositors, consumers, and investors. H.R. 4173, "the Wall Street Reform and Consumer Protection Act" and S. 3217, "the Restoring American Financial Stability Act" (Committee Print) - The Forum supports financial regulatory reform that would: 1) establish resolution authority to end "too-big-to-fail", 2) enhance consumer protections; 3) regulate over-the-counter derivatives; and, 4) designate a "systemic supervisor." The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, believes that imposing haircuts on secured creditors to financial institutions in resolution would introduce systemic risk into the financial system, supports maintaining the establishment of uniform national banking to ensure an efficient banking system, opposes calculating risk based deposit assessments on an insured depository's total assets rather than total domestic deposits, supports retaining supervisory authority of the Federal Reserve and supports post-funding of a new systemic risk resolution fund. The Forum supports risk retention requirements for mortgage originators and securitizers and establishing a new Office of Insurance within the Treasury Department. The Forum supports enhancement of consumer protection and believes that it should be a part of the policy response to the financial crisis. The Forum supports working with policy makers to ensure that consumers, depositors, investors, and policyholders enjoy the world's most steadfast and effective protection of their interests. The Forum supports executive compensation policies that reward attention to risk management and aligns incentives with the long-term viability and safety and soundness of financial institutions. H.R. 4375 & S. 2886, "the Glass-Steagall Restoration Act" - The Forum supports retaining a provision in "the Gramm-Leach-Bliley Act" that allows for the creation of financial holding companies (FHC) in which the FHC serves as an umbrella corporation for other financial subsidiaries. The Glass-Stegall Restoration Act would repeal this provision. The financial holding company structure structure did not contribute to the financial crisis. The Forum believes the appropriate policy response is enhanced supervision to minimize financial instability, coupled with resolution authority to end "too-big-to-fail." H.R. 3795, the Over the Counter Derivatives Markets Act, H.R. 2454, "the American Clean Energy and Security Act," H.R. 2448 "the Prevent Unfair Manipulation of Prices Act," H.R. 977, "the Derivatives Markets Transparency and Accountability Act" - Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum believes that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. APEC Privacy Framework - The Forum supports an APEC Privacy Framework that does not unduly restrict the global flow of data which is vital for financial institutions to meet customer needs and serve them efficiently. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness and systemic stability while not undermining lending that stimulates economic growth and job creation. Capital Market Competitiveness generally - The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy.

Financial Regulatory Reform and Modernization - The Forum supports modernization and reform of the financial regulatory system to ensure the safety and soundness of financial institutions, the stability of the U.S. financial system and the protection of the varied interests of depositors, consumers, and investors. H.R. 4173, the "Wall Street Reform and Consumer Protection Act" and S. 3217, the "Restoring American Financial Stability Act" (Conference Report) - The Forum supports financial regulatory reform that would: 1) establish resolution authority to end "too-big-to-fail", 2) enhance consumer protections, 3) regulate over-the-counter derivatives; and, 4) designate a "systemic supervisor." The Forum opposes legislation to preemptively dismantle or limit the activities of well-capitalized and well-managed financial institutions, believes that imposing haircuts on secured creditors to financial institutions in resolution would introduce systemic risk into the financial system, supports maintaining the establishment of uniform national banking to ensure an efficient banking system, supports retaining supervisory authority of the Federal Reserve and supports post-funding of a new systemic risk resolution fund. The Forum supports risk retention requirements for mortgage originators and securitizers and establishing a new Office of Insurance within the Treasury Department. The Forum supports enhancement of consumer protection. The Forum supports working with policy makers to ensure that consumers, depositors, investors, and policyholders enjoy the world's most steadfast and effective protection of their interests. The Forum supports executive compensation policies that reward attention to risk management and aligns incentives with the long-term viability and safety and soundness of financial institutions. Derivatives are important tools that enable companies to minimize and manage their exposure to a wide range of risks, thereby freeing up vital capital for other uses. The Forum believes that financial derivatives should be subject to prudential supervision and supports the establishment of a systemic risk supervisor to monitor, assess and address systemic risk, in continuous interaction with functional regulators to address any threats to the financial system, including in the derivatives markets. H.R. 4375 & S. 2886, the "Glass-Steagall Restoration Act" - The Forum supports retaining a provision in the "Gramm-Leach-Bliley Act" that allows for the creation of financial holding companies (FHC) in which the FHC serves as an umbrella corporation for other financial subsidiaries. The Glass-Steagall Restoration Act would repeal this provision. The financial holding company structure did not contribute to the financial crisis. The Forum believes the appropriate policy response is enhanced supervision to minimize financial instability, coupled with resolution authority to end "too-big-to-fail." APEC Privacy Framework - The Forum supports an APEC Privacy Framework that does not unduly restrict the global flow of data which is vital for financial institutions to meet customer needs and serve them efficiently. Capital Requirements - The Forum supports regulatory capital requirements that ensure safety, soundness, and systemic stability while not undermining lending that stimulates economic growth and job creation. Capital Market Competitiveness generally - The Forum supports the free flow of capital and open and competitive U.S. markets. The Forum also supports maintaining the United States as an attractive place for investment and a continued leader in the global economy.