Relentless Pressure and Resulting Concession

On Friday, the Federal Reserve offered an olive branch – small and partial, but still a branch – to Republican critics of pending standards and the big banks powering up all this pain.  As we noted, the comment deadlines for the capital and GSIB-surcharge rules have been extended to January 16, a move also designed to thwart litigation based on procedural considerations.  The Fed has also announced a new data-gathering exercise in which stakeholders can send in “data” but due to which much more input will also surely flow.  This exercise also answers procedural critics and protects the bill, with the deadline here also January 16.

Al102323.pdf