Legal Seminar, Chicago, IL

CSBS PROPOSED “ENHANCED” PRUDENTIAL STANDARDS

Capital: Commensurate with the risk in the entire firm

Liquidity: More liquidity as needed and better monitoring of needs

Stress Testing: The process should inform the firm’s ability to maintain sufficient capital and liquidity throughout times of economic and financial stress.

Living Will and Recovery Resolution Plans

• Liquidity: We need to consider substantive targets and metrics for both servicing liquidity and operating liquidity.

Nonbank Enforcement Strategy

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