Research Advocacy and Policy

INTRODUCTORY WEB SEMINAR

Banking Regulation, Supervision, and Examination (Approximately 1 hour). Contents include: Federal banking regulation overview, including Federal Reserve, FDIC and CPFB regulations; state and local law and regulation; banking supervision and examination; exam process; enforcement actions.


ACCOUNTING; CECL

Summary of RMA-Hosted CECL Conference Call (PDF) held on August 11, 2017, with the Regulatory Chief Accountants from the Federal Deposit Insurance Corporation, Federal Reserve Board, and the Office of the Comptroller of the Currency.

Interagency Frequently Asked Questions on CECL Implementation (PDF) dated December 19, 2016 to assist institutions and examiners with the new accounting standard, Accounting Standards Update 2016-13, Topic 326, “Financial Instruments – Credit Losses”, issued by the Financial Accounting Standards Board (FASB) on June 16, 2016.

Regulatory Joint Statement on the New Accounting Standard (CECL) (PDF)  Issued June 17, 2016 by The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC).


CAPITAL AND LIQUIDITY

Community Bank Council Comment Letter (PDF) dated September 28, 2012, to the Federal Reserve Board of Governors, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation regarding Regulatory Capital Rules (i) Implementation of Basel III, Minimum Regulatory Capital Ratios, Capital Adequacy, Transition Provisions, and Prompt Corrective Action, Docket ID OCC-2012-0008; Docket No. R-[XX]; RIN 3064-AD95 (the “Basel III NPR”), and (ii) the Standardized Approach for Risk-weighted Assets; Market Discipline and Disclosure Requirements, Docket ID OCC-2012-0009; Docket No. [XX] [XX]; RIN3064-AD96.


CREDIT RISK

Response of the Risk Management Association's Community Bank Council and Mid-Tier Bank Council (PDF) dated January 18, 2019 Re: Request for Information on Small-Dollar Lending.

Consumer Finance Protection Bureau (CFPB) Comment Letter (PDF) from RMA dated October 17, 2016 regarding the "Amendments to Federal Mortgage Disclosure Requirements under the Truth in Lending Act (Regulation Z)," 12 CFR Part 1026, Docket No. CFPB-2016-0038,RIN 3170-AA61. 

White Paper dated October 24, 2013 by RMA regarding Consequences of Final U.S. Basel III Rule on Eligible Guarantors and Eligible Guarantees (PDF)

Chief Appraisers Roundtable Comment Letter dated November 29, 2012, to FFIEC Appraisal Subcommittee regarding Proposed Policy Statements; Docket No. AS12-16 (PDF)

Policy Statement on Prudent Commercial Real Estate Workouts (PDF) issued October 30, 2009, by the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDCIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), the Office of Thrift Supervision (OTS), and the Federal Financial Institutions Examination Council (FFIEC) State Liaison Committee (collectively, the regulators).

Concentrations of Credit booklet (PDF) CRE Guidance Response: Concentrations in Commercial Real Estate Lending, Sound Risk Management Practices (PDF)


ENTERPRISE RISK MANAGEMENT

March 14, 2018, (PDF) Comment letter from RMA to the Board of Governors of the Federal Reserve System regarding the  "Proposed Guidance on Core Principles of  (I) Effective Senior Management; (ii) Management of Business Lines; and (iii) Independent Risk Management and Controls," Proposed Guidance issued by the Board of Governors, Docket ID OP-1594.

August 3, 2017, (PDF) letter from RMA to the Board of Governors of the Federal Reserve System regarding the Proposed Guidance issued by the Board of Governors, Docket ID OP-1570, "Proposed Guidance on Supervisory Expectations for Boards of Directors" (the "Proposed Guidance")

March 25, 2014, (PDF) letter from RMA to the Office of the Comptroller of the Currency regarding OCC-2014-0001, "OCC Guidelines Establishing Heightened Expectations for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Integration of 12 C.F.R. Parts 30 and 170." 


LEGAL RISK

 August 16, 2016, RMA Comment letter to the Consumer Financial Protection Bureau (PDF) Regarding the Proposed Rule "Arbitration Agreements,"12 CFR Part 1040, Docket No. CFPB-2016-0020, RIN 3170-AA51.

December 16, 2010 letter (PDF) from RMA to the Securities and Exchange Commission regarding the Proposed Rules for "Implementing the Whistleblower Provisions of the Dodd–Frank Act."

Amicus Curie Brief (PDF) filed by The Risk Management Association in the Wisconsin Court of Appeals in the matter of Michael S. Polsky, as receiver for Communications Product Corporation v. Daniel E. Virnich and Jack M. Moores, Appeal No. 2007AP000203.

 

MARKET RISK

December 5, 2009, letter from RMA (PDF) to U.S. Representative Brad Miller, Chairman and US Representative Paul Broun, Ranking Member of the House Committee on Science and Technology Subcommittee on Investigations and Oversight, relating to the use of risk models. (PDF)


OPERATIONAL RISK

May 25, 2018 (PDF), comment letter, This  letter  is  submitted   by  the  Advanced   Operational   Risk  Group   ("AORG") of The Management Association ("RMA" or the "Association") in respect of the Consultative Document Pillar 3 disclosure requirement - updated  framework" issued by the Basel Committee on Banking Supervision in February 2018 (the "Disclosure Requirements").

January 13, 2017 (PDF), comment letter, to Robert deV. Frierson, Secretary, Board of Governors of the Federal Reserve System. Re: Enhanced Cyber Risk Management Standards (the "ANPR").

November 15, 2016 (PDF) comment letter, to Robert deV. Frierson, Secretary, Board of Governors of the Federal Reserve System FAQ response (#Y140000274) included in the Federal Reserve Boards (FRB) FAQ release dated October 3, 2016.

July 20, 2016 (PDF), letter from RMA to the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, et al regarding Incentive-based Compensation Arrangements 12 CFR Parts 42; 236; 372; etc.

June 1, 2016 (PDF), letter from RMA to the Basel Committee on Banking Supervision, Bank for International Settlements regarding the Consultative Document entitled “Standardized Approach for Operational Risk”.

September 10, 2014 (PDF), Supplemental AMAG Comment on 2014 Agency Information Collection Proposals Operational Risk Data Reporting FR Y-14A/Q/M - OMB No. 7100-0341

August 21, 2014 (PDF), Letter from the Risk Management Association and The Clearing House Association L.L.C., Re: Proposed Agency Information Collection Activities; Comment Request: Capital Assessments and Stress Testing Information Collection (79 Fed. Reg. 41,276 July 15, 2014 – OMB control number: 7100–0341)

August 19, 2014 (PDF), AMAG Comment on 2014 Agency Information Collection Proposals Operational Risk Data Reporting FR Y-14A/Q/M – OMB No. 7100-0341

December 18, 2013 (PDF), Letter from The Risk Management Association to the office of the Comptroller of the Currency regarding OCC 2013-29, Third Party Relationships

August 6, 2012 (PDF), The Clearing House Association L.L.C., The Risk Management Association/the Advanced Measurement Approaches Group, the Financial Services Roundtable, and the American Bankers Association Joint Comment Letter re: FR Y–14A/Q/M OMB Control Number: 7100–0341. (Capital Plans; Proposed Agency Information Collection Activities)

August 6, 2012 (PDF), AMAG 2nd Supplemental Response 2012 Agency Information Collection Activities Operational Risk Data Reporting FR Y-14A/Q/M – OMB Nos. 7100-0341

May 24, 2012 (PDF), AMAG Supplemental Response 2012 Agency Information Collection Activities Operational Risk Data Reporting FR Y-14A/Q/M – OMB Nos. 7100-0341 and 7100-0319

April 23, 2012 (PDF), AMAG Comments on 2012 Agency Information Collection Activities Operational Risk Data Reporting FR Y-14A/Q/M – OMB Nos. 7100-0341 and 7100-0319

February 29, 2012 (PDF), "Interagency Guidance on the Advanced Measurement Approaches for Operational Risk”

February 5, 2010 (PDF), letter from RMA to the Basel Committee, regarding the consultative document, “Recognizing the Risk-mitigating impact of Insurance in Operational Risk Modeling”

Advanced Measurement Approach Group Industry Position Paper, Business Environment and Internal Control Factors (BEICFs) (PDF)

Advanced Measurement Approach Group Industry Position Paper, Unit of Measure and Dependence (PDF)


SECURITIES LENDING


November 27, 2013 (PDF), Comment Letter – Consultative Document on Strengthening Oversight and Regulation of Shadow Banking

September 20, 2013 (PDF), Comment Letter – Revised Basel III leverage ratio framework and disclosure requirements.

January 14, 2013 (PDF), Comment Letter – Proposed Policy Framework for Addressing Shadow Banking Risks in Securities Lending and Repos.

September 26, 2012 (PDF), Comment Letter to FSB’s Thematic Peer Review on Resolution Regimes.

May 25, 2012 (PDF), ISLA, RMA, and PASLA joint response to the Interim Report of the FSB Workstream on Securities Lending and Repos.

February 10, 2011 (PDF), comment letter submitted to the U.S. Treasury on Section 6045A Transfer Statements.

October 20, 2010 (PDF), letter from RMA’s Executive Committee on Securities Lending to the Securities and Exchange Commission relating to the Concept Release on the U.S. Proxy System, together with A Report to Market Participants and Regulators Regarding Proxy Voting Practices and Issues dated October 2010.

September 20, 2010 (PDF), letter from RMA’s Executive Committee on Securities Lending to the Internal Revenue Service in response to certain requirements contained within the proposed cost basis reporting regulations to be issued pursuant to The Energy Improvement and Extension Act of 2008.

May 27, 2010 (PDF), letter from RMA’s Executive Committee on Securities Lending to State of New York Insurance Department in response to the Department’s circular letter on prudent securities lending practices.

September 25, 2009 (PDF), letter from RMA’s Executive Committee on Securities Lending and The Securities Lending Division (SLD) of the Securities Industry and Financial Market Association to the Securities and Exchange Commission relating to the current state of the U.S. securities lending markets, notions of a centralized marketplace for securities lending as well as a securities lending