Synchrony Financial

Summary: Synchrony Financial supports the Agencies' objectives to promote a resilient banking system and welcomes the revisions to the capital framework that better align requirements with underlying risk. However, the company requests specific adjustments to ensure the rule is operationally workable and tailored for Category III/IV firms, such as decoupling DTA deduction frameworks from ERBA elections and maintaining a 0% credit conversion factor for retail credit card commitments.