Comments to the Federal Reserve Regarding Docket No. R–1775: Proposed Regulation Implementing the LIBOR Act
We strongly support the Board’s proposed rule, particularly the determination that no conforming changes are needed for consumer loans. But we recommend two clarifications for non-covered consumer contracts: a) declare that the Board-selected benchmark replacement for non-covered consumer contracts is the same as the replacement selected for covered consumer contracts; and b) adopt a rule…