SFA Submits Advocacy Letter Under the EGRPRA Act
article by Structured Finance Association
On October 3, 2025, the Structured Finance Association commented on the fourth joint notice of regulatory review and request for comment under Section 2222 of the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (“EGRPRA”), issued by the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (collectively, the “Agencies”).
In their Request for Comment, the Agencies requested comment on “regulations in the Banking Operations, Capital, and the Community Reinvestment Act categories to identify outdated, unnecessary, or unduly burdensome requirements for insured depository institutions and their holding companies.”
In this letter, SFA focuses on two particularly consequential opportunities for modernization and burden reduction and offers corresponding recommendations:
- The capital rule should fully recognize the credit risk mitigation benefits of credit-linked notes issued directly by banks; and
- The Agencies should update the GFC-era calibration of the Simplified Supervisory Formula Approach (“SSFA”).