On May 21, FIA responded to a proposal issued in April by the Federal Reserve and the Office of the Comptroller of the Currency that aims to tailor leverage ratio requirements for the largest U.S. banks to their business activities and risk profiles. FIA's comments express support for the proposal as a first step, but stress a need for further reforms in the treatment of cleared derivatives. Areas FIA highlighted include recognizing the exposure-reducing effect of initial margin, adopting a modified SA-CCR methodology, and eliminating double counting in the surcharge methodology.
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