Marsh

MarshSupportAdvocacy
Summary: Marsh, a global risk and reinsurance firm, supports the proposed rule but argues that the definition of "eligible guarantor" should be clarified to include investment-grade operating subsidiaries of larger organizations. They argue this change would align the rule with the economic reality of the (re)insurance industry and provide smaller community banks with better access to credit risk transfer (CRT) solutions.
Please find Marsh comments on "Category I and II Banking Organizations, Banking Organizations with Significant Trading Activity, and Optional Adoption for Other Banking Organizations."

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