U.S. Chamber Letter to Federal Reserve Board on Holistic Capital Review

The U.S. Chamber of Commerce (“Chamber”) writes to address the Federal Reserve Board’s (“Board”) review of the supervision and regulation of Silicon Valley Bank (“SVB”), its ongoing Holistic Capital Review, and any actions that the Board may pursue as a result of its findings. The Board’s report analyzing the causes of failure at SVB is critical to informing the public and understanding whether any regulations should be updated. We commend the Board for conducting the review of SVB but were surprised by statements suggesting, without evidence, that increased capital and liquidity requirements may be in order given the report also in part faults the failure of SVB bank management and supervision. Given the important role of banks in financing main street economic growth, capital markets activities, business lending, and cash management, we ask that the Board similarly embrace transparency as it finalizes its Holistic Capital Review and takes steps to implement the Basel III endgame.