Seeking Comment on the Minneapolis Plan to End Too Big to Fail

The Federal Reserve Bank of Minneapolis welcomes feedback on all aspects of the Minneapolis Plan. Commenters can also provide feedback on the following specific questions:

  1. Benefit and Cost Analysis of Higher Minimum Equity Requirement

    The Minneapolis Plan would increase the minimum equity requirement for banks with assets over $250 billion, reflecting an underlying analysis of the benefits and costs of higher capital.

    (Q1) Are there improvements that the Federal Reserve Bank of Minneapolis could make to its calculation of the benefits of this aspect of the proposal?
    (Q2) Are there improvements that the Federal Reserve Bank of Minneapolis could make to its calculation of the costs of this aspect of the proposal?
    (Q3) Are there improvements that the Federal Reserve Bank of Minneapolis could make to its proposed minimum equity requirement for large banks?

  2. Benefit and Cost Analysis of a “Systemic Risk Capital Charge”

    The proposal would create a Systemic Risk Capital Charge for all firms that the Financial Stability Oversight Council fails to certify as no longer systemically important.

    (Q4) Are there improvements that the Federal Reserve Bank of Minneapolis could make to its calculation of the benefits of this aspect of the proposal?
    (Q5) Are there improvements that the Federal Reserve Bank of Minneapolis could make to its calculation of the costs of this aspect of the proposal?
    (Q6) Are there improvements that the Federal Reserve Bank of Minneapolis could make to its proposal calling on the Treasury Secretary to certify that firms are no longer systemically important?
    (Q7) Are there alternative frameworks the Federal Reserve Bank of Minneapolis could use in reducing systemic risk of large financial firms?

  3. Setting a Shadow Bank Tax

    The proposal would levy a tax on shadow banks.

    (Q8) Are there improvements that the Federal Reserve Bank of Minneapolis could make to setting a tax on shadow banks within the framework set forth in the proposal?
    (Q9) Are there alternative frameworks the Federal Reserve Bank of Minneapolis could use in setting a tax on shadow banks? What are they? How would a fee be calculated using these alternative frameworks? Why are they superior to the framework used in the proposal?

  4. Right Sizing Community Bank Supervision and Regulation

    The proposal would create a separate and more appropriate supervisory and regulatory regime for community banks.

    (Q10) Are there specific features of such a regime that the current proposal should include but does not?
    (Q11) Are there specific features of such a regime that the current proposal includes that it should not?

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