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Letters

Hal S. Scott Submits Follow Up Letter To Senate Hearing on High Frequency Trading

On July 7, 2014, Prof. Hal S. Scott submitted a letter to Senators Mark Warner and Mike Johanns, Chair and Ranking Member, respectively, of the Subcommittee on Securities, Insurance, and Investment of the US Senate Committee on Banking, Housing, and Urban Affairs. In that letter Prof. Scott addressed two critical points that

Committee Submits Letter on Supplemental Leverage to Fed, FDIC, & OCC

Cambridge, Mass., June 12, 2014 – The Committee on Capital Markets Regulation today submitted a letter to the Federal Reserve, FDIC and Office of the Comptroller of the Currency critiquing their Proposed Rule to the Supplementary Leverage Ratio. The CCMR had previously also commented on leverage ratios here in October 2013.

Committee Submits Letter on Non-bank Non-Isurer G-SIFI Methodologies to FSB/IOSCO

  CAMBRIDGE, Mass., April 7, 2014 — The Committee on Capital Markets Regulation today submitted a comment letter to the Financial Stability Board/International Organization of Securities Commissions (FSB/IOSCO) critiquing their Consultative Document regarding assessment methodologies for identifying non-bank non-insurer G-SIFIs. To view the full text of the Committee’s letter download it at right.

Committee Submits Letter on Emergency Lending Proposal to Federal Reserve

CAMBRIDGE, Mass., March 5, 2014 — The Committee on Capital Markets Regulation today submitted a comment letter to the Federal Reserve critiquing their Proposed Rule  ”Extensions of Credit by Federal Reserve Banks, 79 Fed. Reg. 615.” The comment letter raises concerns regarding emergency lending pursuant to section 13(3) of the Federal Reserve Act.

Committee Submits Letter on Convertible Debt Withholding Tax to IRS

CAMBRIDGE, Mass., March 5, 2014 — The Committee on Capital Markets Regulation today submitted a comment letter to the IRS critiquing their Proposed Rule entitled “Section 871 (m)-Dividend Equivalents From Sources Within the United States.” The Committee raises concerns that the Proposed Rule would negatively effect the attractiveness of convertible debt to foreign investors.