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Q 60: The agencies are interested in commenters’ views on other business lines or event types in which highly predictable, routine losses have been observed.

Q 61: The agencies seek commenters’ views on all of the elements proposed to be captured through the public disclosure requirements. In particular, the agencies seek comment on the extent to which the proposed disclosures balance providing market participants with sufficient information to appropriately assess the capital strength of individual institutions, fostering comparability from bank to bank, and reducing burden on the banks that are reporting the information.

Q 62: Comments on regulatory reporting issues may be submitted in response to this NPR as well as through the regulatory reporting request for comment noted above.

CFG/RBS Comments The following areas are worthy of further consideration:

  • Commercial/business credit card fraud: Citizens currently treats commercial/business credit card fraud as an operational loss for capital calculation. We believe that the NPR should allow business cards to be treated the same as retail card fraud.

  • HELOCs: can include both credit and operational losses depending on circumstances (e.g. if fraud exists), and that for capital purposes it may be appropriate to separate operational losses from credit losses when the classification can be clearly determined.

Our plans for Pillar 3 disclosures are well advanced (as required by the Basel Committee) at the Group level. Any requirements that force subsidiaries to also publish Pillar 3 disclosures are super equivalent to the Basel requirements. Equally, such additional requirements will fall disproportionately to EU firms with US subs. Given the current level of regulatory and statutory disclosure, any additional work is unlikely to improve the understanding of the


The current wording around “for each of the last three years… since the bank entered its first floor period” is misleading. It is not possible to calculate or publish detailed Pillar 3 data for the period before parallel run, as it does not exist. It is possible to publish the capital indices, but even this will be problematic given changes in the capital definition over time. Simply, firms should be required to adopt Pillar 3 when they go live on the minimum capital requirements under Pillar 1. Any other proposal is unrealistic.

It is not possible to comment without sight of the proposed Regulatory Returns.


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