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<h3>Introduction</h3>Just as the world is coming out of a 100-year pandemic, still uncertain what the “new normal” will be, we are now facing considerable economic headwinds. &nbsp;Inflation has climbed to a 40-year high. &nbsp;Interest rates are rising.&nbsp; Geopolitical events threaten to upend how the global economy has functioned for decades. &nbsp;Supply chain disruptions persist.&nbsp; Bottom line: while the worst of COVID appears behind us, there are a lot of unknowns in the world today.To get through this unpredictable and volatile time, the U.S. capital markets – and the businesses, workers, and families that depend on them – need certainty, stability, and prudence from Washington.&nbsp; Unfortunately, the Securities and Exchange Commission (SEC) is pursuing an unprecedented rulemaking agenda that could compound our current challenges and result in adverse consequences for the real economy in terms of output, employment, investment, and prices.&nbsp;<h3>The SEC’s Agenda is Unprecedented and Presents a Number of Risks&nbsp;&nbsp;</h3>As of last fall, the SEC had 54 separate items on its rulemaking agenda, according to the Office of Information and Regulatory Affairs’ (OIRA).&nbsp; This represents “one of the most ambitious agendas in the SEC’s 87-year history,” according to Bloomberg. &nbsp;In fact, in just the first quarter of 2022, the SEC issued 16 new rule proposals, which is only the third time in the 21st Century that it has put out more than 8 new rules in Q1.&nbsp; In the first quarter of 2004 and 2011, the SEC released, respectively, 16 new rules following the accounting and corporate scandals of Enron and WorldCom and 17 new rules following the global financial crisis and Dodd-Frank Act.&nbsp; Excluding 2004, 2011, and 2022, the SEC has issued an average of 3.3 new first-quarter rule proposals since 2000.&nbsp; Unlike those two previous periods, the 16 SEC rules that were released in Q1 2022 are not responding to a major crisis driven by financial institutions, markets or public companies.&nbsp; Rather, financial institutions and markets have been a helpful and important source of strength and stability during the challenge of the past few years.&nbsp;In addition to the sheer volume of changes being proposed, the SEC is limiting public comment in an unprecedented way.&nbsp; Historically, the SEC has given the public between 60 and 90 days to comment on most rule proposals after they are published in the Federal Register. &nbsp;During the tenure of Chair Mary Jo White (2013 – 2017), the public had 60 days to comment on rule proposals 82 percent of the time and 90 days 14 percent of the time.&nbsp; Similarly, under Chair Jay Clayton (2017 – 2020), the SEC used 60-day and 90-day public comment periods 76 percent and 9 percent of the time, respectively.&nbsp; By contrast, under the current Chair &nbsp;- Gary Gensler - &nbsp;the SEC has provided 60-day comment periods only 7 percent of the time, and on average the public has had only 38 days to review and comment on a rule proposal.The volume and velocity of SEC rulemaking (<a href="https://www.sec.gov/rules/proposed.shtml">https://www.sec.gov/rules/proposed.shtml</a>) are especially concerning given that many of the proposed rules include sweeping changes that could require significant shifts in industry operations and practices.&nbsp; Such large-scale changes to an array of markets entails significant risk.&nbsp; Anytime the underlying “rules of the road” are changed significantly there is an increase in uncertainty as markets and investors respond to the new “rules of the road”.&nbsp; Large scale changes to the “rules of the road” across many markets increases regulatory uncertainty and risks depressing economic activity.<h3>Rising Policy Uncertainty Presents Risk to the Economy</h3>In the past ten years, economists have rigorously measured economic policy uncertainty and its impact on the U.S. economy.&nbsp; The evidence clearly shows that policy uncertainty has been rising steadily for more than a decade, both when assessed by broad measures of overall economic policy uncertainty that include tax and trade policy, as well as by narrower measures of regulatory policy uncertainty.&nbsp; The table below shows the increase in broad economic policy uncertainty and regulatory policy uncertainty taken from research-based policy uncertainty <a href="https://www.policyuncertainty.com/index.html">indexes</a> constructed by economists from Northwestern University, Stanford University and the University of Chicago.&nbsp;<figure class="table" style="width:472.25pt;"><table style="border-bottom:none;border-left:none;border-right:none;border-top:none;"><tbody><tr><td style="border-bottom:1.0pt solid windowtext;border-left:1.0pt solid windowtext;border-right:1.0pt solid windowtext;border-top:1.0pt solid windowtext;padding:0in 5.4pt;vertical-align:top;width:472.25pt;" colspan="3">U.S. Policy Uncertainty: 1985-2022</td></tr><tr><td style="border-bottom:1.0pt solid windowtext;border-left:1.0pt solid windowtext;border-right:1.0pt solid windowtext;border-top:1.0pt none windowtext;padding:0in 5.4pt;vertical-align:top;width:155.8pt;">&nbsp;</td><td style="border-bottom:1.0pt solid windowtext;border-left:none;border-right:1.0pt solid windowtext;border-top:none;padding:0in 5.4pt;vertical-align:top;width:155.85pt;">Economic Policy Uncertainty</td><td style="border-bottom:1.0pt solid windowtext;border-left:none;border-right:1.0pt solid windowtext;border-top:none;padding:0in 5.4pt;vertical-align:top;width:160.6pt;">Regulatory Policy Uncertainty</td></tr><tr><td style="border-bottom:1.0pt solid windowtext;border-left:1.0pt solid windowtext;border-right:1.0pt solid windowtext;border-top:1.0pt none windowtext;padding:0in 5.4pt;vertical-align:top;width:155.8pt;">1985-2009</td><td style="border-bottom:1.0pt solid windowtext;border-left:none;border-right:1.0pt solid windowtext;border-top:none;padding:0in 5.4pt;vertical-align:top;width:155.85pt;">100</td><td style="border-bottom:1.0pt solid windowtext;border-left:none;border-right:1.0pt solid windowtext;border-top:none;padding:0in 5.4pt;vertical-align:top;width:160.6pt;">100</td></tr><tr><td style="border-bottom:1.0pt solid windowtext;border-left:1.0pt solid windowtext;border-right:1.0pt solid windowtext;border-top:1.0pt none windowtext;padding:0in 5.4pt;vertical-align:top;width:155.8pt;">2010-2022</td><td style="border-bottom:1.0pt solid windowtext;border-left:none;border-right:1.0pt solid windowtext;border-top:none;padding:0in 5.4pt;vertical-align:top;width:155.85pt;">119</td><td style="border-bottom:1.0pt solid windowtext;border-left:none;border-right:1.0pt solid windowtext;border-top:none;padding:0in 5.4pt;vertical-align:top;width:160.6pt;">133</td></tr><tr><td style="border-bottom:1.0pt solid windowtext;border-left:1.0pt solid windowtext;border-right:1.0pt solid windowtext;border-top:1.0pt none windowtext;padding:0in 5.4pt;vertical-align:top;width:472.25pt;" colspan="3">Source: <a href="http://www.policyuncertainty.com">www.policyuncertainty.com</a></td></tr></tbody></table></figure>&nbsp;What is the impact of this policy uncertainty on the economy?&nbsp; Again, peer reviewed economic research has explored this question, and the findings are significant.&nbsp; Economists find that heightened uncertainty has a real and significant negative effect on economic performance.&nbsp; Specifically, in “<a href="https://nbloom.people.stanford.edu/sites/g/files/sbiybj4746/f/qje_bbd.pdf">Measuring Economic Policy Uncertainty</a>”, Scott R. Baker, Nicholas Bloom, and Steven J. Davis find “that policy uncertainty is associated with greater stock price volatility and reduced investment and employment in policy-sensitive sectors like defense, healthcare, finance and infrastructure construction.&nbsp; At the macro level, innovations in policy uncertainty foreshadow declines in investment, output, and employment in the United States.”&nbsp; These findings are important, especially given the considerable social, geopolitical, and economic uncertainties facing the world today.Injecting regulatory uncertainty into many aspects of the U.S. capital markets could result in adverse consequences.&nbsp; The process of implementing large-scale changes to federal regulations, like those issued by the SEC, can take several years and is often marked by deep uncertainty caused by litigation challenges and the need for further rulemaking to clarify inconsistencies or resolve problems in the original rule that surface during implementation. In such conditions, investors, securities firms, and other market participants might respond to heightened uncertainty over the “rules of the road” by pulling back from investing in securities and bonds, which could make it harder and more expensive for businesses to raise capital and, in turn, impact the employees and customers of business across every sector of the economy.&nbsp; Companies might be forced to wait to offer new products, invest in infrastructure, and generally be more cautious about their investment and hiring decisions.The harmful effects of rising policy uncertainty underscore the danger of simultaneously implementing a large number of interrelated, untested policy changes and point to the need for the SEC to streamline and prioritize its regulatory agenda.&nbsp; &nbsp;&nbsp;<h3>An Aggressive and Accelerated Regulatory Agenda Risks Market Stability and Investor Confidence</h3>SEC rulemaking does not occur in a vacuum.&nbsp; The capital markets have long been one of the most regulated sectors of our economy.&nbsp; Chart 1 shows the multitude of new regulations issued by the SEC and other federal agencies impacting participants in the capital markets. &nbsp;Implementing all these new rules on a compressed timeline has the potential to create risk by overtaxing technological, operational, and compliance resources of financial institutions of all sizes.Designing and implementing each of these proposals individually – let alone all at the same time – is a major regulatory undertaking that needs thoughtful consideration, especially given the state of the global economy today. &nbsp;Accelerating these rules through the regulatory process impairs the SEC’s ability to fully analyze the proposals and understand their possible adverse consequences.&nbsp;A case in point is proposed rule 10B-1, which sets forth security-based swap (SBS) position reporting requirements.&nbsp; As noted extensively in the public comments, the SEC’s cost-benefit analysis of 10B-1 does not account for several significant potential adverse impacts. &nbsp;For example, the Council for Investor Rights and Corporate Accountability <a href="https://www.sec.gov/comments/s7-32-10/s73210-20120747-272911.pdf">stated</a>, the SEC “fails to evaluate the chilling effect that the Proposed Rule will have on activist investors and the harmful collateral effects that a reduction of such corporate activism will have on retail investors and other stakeholders.” &nbsp;Other commenters noted that the SEC did not analyze the proposal’s impact in terms of curtailed market activity, reduced liquidity, and constrained capital formation for issuers and borrowers.But these comments, and many more like them, do not account for the “unknown unknowns” – the unintended consequences of new regulations that are impossible to foresee in advance.&nbsp; Will changing SPAC regulations hinder capital raising?&nbsp; Will changing aspects of reporting securities lending arrangements and short sale activity impact stock market liquidity?&nbsp; The number and potential impact of these unintended consequences increase with the interconnectedness of our financial system and the broader economy.<h3>SEC Rules Have Far-Reaching Effects Across Our Interconnected Financial System and Economy</h3>A central lesson of the 2008 financial crisis was that there are deep, complex, and often hard to anticipate interconnections within our financial system and across the broader economy.&nbsp; This interconnectedness increases the risk that the SEC’s current “everything rulemaking agenda” will lead to harmful unintended consequences. &nbsp; &nbsp;Consider the SEC’s money market mutual fund proposal.&nbsp; Money market funds are a key source of banks’ short-term wholesale funding, but this proposal could impede banks’ ability and willingness to utilize them, especially in the context of swing pricing.&nbsp; Banks, therefore, might be forced to rely more on longer term funding, which likely would increase funding costs.&nbsp; If this scenario materializes, banks will have to either pass on the higher funding cost to the real economy or risk lower earning ability which in turn could negatively impact capital ratios.<a href="https://www.sec.gov/oca/staff-accounting-bulletin-121">SEC Staff Accounting Bulletin No. 121</a>, though not a formal rulemaking, could also have unintended impacts.&nbsp; This staff-level guidance has the potential to force financial institutions that custody crypto-assets to bring these crypto-assets on balance sheet for accounting purposes.&nbsp; If these financial institutions also are bank affiliates subject to prudential regulations, the SEC’s SAB could have direct prudential capital consequences.As we learned in 2008, many interconnections within our financial system and across the economy only become visible in a stressed environment.&nbsp; And a significant body of economic research suggests that rushing through a multitude of sweeping regulatory changes simultaneously could contribute to such stressed conditions.<h3>A Well Thought-Out, Measured &amp; Prioritized Agenda Is the Most Prudent Approach</h3>We believe a more prudent approach to the “everything rulemaking agenda” is for the SEC to prioritize the most pressing regulatory issues that support market resilience and efficiency and to allow for more meaningful stakeholder input and evaluation of rule proposals’ cumulative impacts.&nbsp; In doing this the SEC should consider not only each individual issue, but also its possible connection with other issues and how any proposed changes might compound our current economic challenges like inflation.&nbsp; The SEC should also act in a deliberate manner that provides markets and investors with enough time to absorb the impact of new rules so as to moderate the total amount of uncertainty created through the regulatory process.&nbsp; There are certainly areas of our capital markets in need of reform, but any changes must be implemented with caution and care with an eye towards managing and improving the overall financial system.&nbsp;<h3>Chart 1: Implementation for Recently Proposed/Finalized Capital Markets’ Regulations</h3>The chart below illustrates the implementation timeline for a broad range of financial regulations in various stages of proposal or implementation. As shown, the simultaneous implementation of a multitude of rules on a compressed timeline could strain SIFMA members’ resources and has the potential to create risk by overtaxing industry technology, operational, and compliance resources. Financial institutions of all sizes and business models will be impacted by some or all these regulations to varying degrees.&nbsp;Additionally, the timelines are subject to change as the industry adopts new rules and amendments.&nbsp;<figure class="image"><img src="https://fsforum.com/a/media/chart-2.png"></figure>All timelines with relation to proposed rules are SIFMA staff estimates. Certain Banking Regulator deadlines may extend further than Fiscal Year 2025. *Amendments to Exchange Act Rule 3b-16 and Reg ATS Proposal are to be determined. It is too early to specify a timeline. Reg ATS includes U.S. Treasury and Agency Securities, NMS Stocks and Other Securities. **The FINRA Rule 4210 effective date may be significantly delayed by litigation. ***Updates to Short Selling Reporting Proposal are to be determined. It is too early to specify a timeline.

The SEC’s Current Far-Ranging & Aggressive Rulemaking Agenda Will Raise Regulatory Uncertainty and Risks Unintended, Negative Consequences

CONTACT: Brigid Richelieu(202) 660-2569brichelieu@fsforum.com&nbsp;&nbsp;Trade Group Calls for Government and Private Sector to Work Together to Ensure the United States Has a World-Leading Payments SystemWashington, D.C. – Regulators and the private sector should develop public-private partnerships to conduct research and development about new technologies and infrastructures, including a potential central bank digital currency (CBDC), the Financial Services Forum said Friday.Responding to a discussion paper from the Federal Reserve Board (FRB), the Forum urged the FRB to continue to examine the potential risks of a CBDC, as well as alternative ways to achieve the goals associated with a CBDC and an enhanced payments system. The Forum further encouraged the FRB to consider the appropriate legal and regulatory development that is necessary to support payment system innovation before adopting any CBDC.“The Forum member institutions are committed to helping to ensure that the United States has a world-leading payments system that allows individuals, households, and businesses to execute financial transactions quickly, securely, and cost-effectively,” Forum President and CEO Kevin Fromer said. “We welcome the FRB’s willingness to engage with a wide range of stakeholders and encourage the FRB to continue to take a deliberate and thoughtful approach to examining this novel and complex change.”The Forum’s letter offered a number of key observations and recommendations regarding the discussion paper and provided responses to specific questions posed by the FRB. The Forum emphasized the importance of evaluating the risks associated with a CBDC, as well as possible mitigants, before determining whether a U.S. CBDC should be a part of the enhanced payments landscape. This type of process would help ensure any such determination is appropriate and would also help inform implementation of any payments system innovations, including a CBDC, the Forum said.&nbsp;The Forum’s full comments can be found <a href="https://fsforum.com/a/media/comment-letter-on-frb-cbdc-discussion-paper.pdf">here.</a>&nbsp;###&nbsp;The Financial Services Forum is an economic policy and advocacy organization whose members are the chief executive officers of the eight largest and most diversified financial institutions headquartered in the United States.&nbsp; Forum member institutions are a leading source of lending and investment in the United States and serve&nbsp;millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system. &nbsp;Visit our website: <a href="http://www.fsforum.com/">fsforum.com</a>Follow us on Twitter <a href="https://twitter.com/fsforum">@fsforum</a> and <a href="https://www.linkedin.com/company/financial-services-forum/">LinkedIn</a>

Forum Submits Comments to Federal Reserve Board Regarding Central Bank Digital Currency

Dear reader,Welcome to the latest edition of The Forum File. In this edition, we are highlighting our firms’ work in helping diverse communities thrive through investments and targeted initiatives.We hope you enjoy reading this edition and please do not hesitate to share your feedback.&nbsp;Kevin Fromer, President and CEO, Financial Services Forum&nbsp;&nbsp;<h2>Penny For Your Thoughts</h2>“Goldman Sachs is committed to advancing diversity, equity and inclusion and we have seen the power of having clear and measurable goals. We continue to create programs that level the playing field and open up opportunities at the firm to an even greater array of talent while remaining transparent and holding ourselves accountable.” – Megan Hogan, Goldman Sachs Chief Diversity Officer&nbsp;&nbsp;<h3>Goldman Sachs launched&nbsp;One Million Black Women&nbsp;about a year ago – what are its latest initiatives or investments?&nbsp;</h3>In March 2021, we launched our landmark inclusive growth initiative, One Million Black Women, committing $10 billion in direct investment capital and $100 million in philanthropic support to address the dual disproportionate gender and racial biases that Black women have faced for generations, exacerbated by the pandemic. This first-of-its-kind investment is led by Black women, partnered with Black women and advised by Black women, and centered on the ultimate goal of radically transforming the futures of Black women and their communities.&nbsp;In January, in partnership with the&nbsp;One Million Black Women&nbsp;Advisory Council, we announced a series of new investments, partnerships and grants directed at 17 leading organizations and projects across the country.This month, we announced the Black Women Impact Grants program, funded by the Goldman Sachs Foundation, to create an open-access grants program for Black women-led and Black women-serving nonprofits. Through the $10 million initiative, 50 Black women-led nonprofits will be selected to receive general operating funding ranging from $50,000 - $250,000 over a two-year period.&nbsp;<h3>What are the firm’s goals around Diversity, Equity and Inclusion?&nbsp;</h3>Hiring, developing and promoting people with a broad and diverse set of experiences and world views are all central to being an employer of choice and serving our clients. We know that diversity and inclusion drive outperformance.In 2019, the firm set aspirational goals for representation when hiring analysts and entry-level associates of 50% women, 11% Black professionals and 14% Hispanic/Latinx in the U.S., and 9% Black professionals in the UK.&nbsp; We have seen strong results including more diverse representation for our 2020 campus analyst class, and the highest representation of Black talent in the Americas.&nbsp;In 2020, we doubled down on these goals by announcing two additional five-year goals to accelerate the recruitment of diverse candidates at all levels of the firm. These are specifically focused on our Vice Presidents and recruits from Historically Black Colleges and Universities (HBCUs).&nbsp;We were proud to announce in November 2021 the most diverse Managing Director class in the history of the firm. We are committed to investing in our people’s development and helping them grow in their careers. We recognize that we still have a long way to go and&nbsp;accountability is at the center of each and every one of these goals.&nbsp;<h3>Goldman Sachs was the first to launch a Returnship program 15 years ago – where is the program now? &nbsp;&nbsp;</h3>We search for talent in new places and always look for diverse backgrounds and experiences for all parts of our firm. We launched the first Returnship program in 2007 based off of our research entitled “Off-ramps and On-ramps,” which focused on challenges and concerns faced by individuals looking to re-enter the workforce.&nbsp;This year we have reimagined our program to support professionals looking to re-start their careers, including those displaced from the workforce due to the COVID-19 pandemic.Through the new direct-to-hire program, returnees will participate in a six-month paid fellowship that provides strong performing candidates with full-time jobs at Goldman Sachs upon successful completion of the program and includes enhanced leadership development and mentorship opportunities.We’re excited to kick off our first cohort of the program this month!&nbsp;<h2>Value Add</h2>Market Madness: HBCU Possibilities Program&nbsp;<figure class="image image_resized" style="width:75%;"><img src="https://fsforum.com/a/media/spelman_college_champions.jpg"></figure>&nbsp;Goldman Sachs believes that diversity is a business imperative.In direct response to our aspirational goal to double the number of campus analysts that the firm recruits from HBCUs by 2025, Goldman Sachs launched the Market Madness: HBCU Possibilities Program last year.The Market Madness: HBCU Possibilities Program is a $25 million, five-year commitment to Historically Black Colleges and Universities. In addition to supporting these institutions, the program provides a semester-long crash course for HBCU students, introducing them to key concepts and careers in finance. Students’ experiences are enriched through mentorship, networking, a financial stipend of $10,000 and the chance to compete in a case study competition with grand prizes ranging from $250,000 to $1 million in grants for their institutions. This year, we expanded the number of HBCUs involved in the program, and 125 students will be competing for the top prize in April in front of our executives.Goldman Sachs is proud to say we have several students who participated in the program last year who will be joining us this summer, and we are excited to continue growing the program in the years to come.&nbsp;<h2>Capital Gains</h2>What we’re doing in Washington&nbsp;&nbsp;After a measure to address “tough legacy” contracts that reference LIBOR was included in the Omnibus Appropriations Bill, the Forum last week issued a <a href="https://fsforum.com/news/financial-services-forum-applauds-inclusion-of-libor-measure-in-omnibus">statement</a> supporting the inclusion and commended senators Tester, Tillis, Brown, Toomey and Representative Sherman for their leadership on this measure.In response to proposals from the <a href="https://fsforum.com/a/media/fsf---occ-climate-principles-comment-letter.pdf">Office of the Comptroller of the Currency</a> and the <a href="https://fsforum.com/a/media/fsf---bcbs-climate-risk-principles-comment-letter.pdf">Basel Committee on Banking Supervision</a>, the Forum commented on efforts to establish guidance for banking organizations to manage climate-related financial risks and offered specific recommendations on how the proposals could be adjusted to further reflect the proposals’ goals.Following the Federal Reserve’s release of its annual bank stress test scenarios, the Forum issued a <a href="https://fsforum.com/news/financial-services-forum-statement-on-2022-stress-test-scenarios">statement</a> highlighting the strength and resiliency of the nation’s largest banks.&nbsp;<h2>Our Two Cents</h2>Research from the Forum&nbsp;The BankNotes Blog Spotlighted:<ul><li><a href="https://fsforum.com/news/focus-on-the-big-picture-addressing-climate-related-financial-risks-within-the-overall-risk-management-framework">Key principles</a> that will promote final principles on climate-related financial risks that are efficient, effective, and well integrated with existing risk-management frameworks, following the requested feedback from the Basel Committee on Banking Supervision and the Office of the Comptroller of the Currency on recently proposed principles for the management and supervision of climate-related financial risks.</li><li>Improving the risk-sensitivity of the <a href="https://fsforum.com/news/basel-iii-finalization-in-the-u-s-context-getting-it-right-trumps-getting-it-done">large bank capital framework</a> is a sensible goal, but reforms that primarily raise capital levels are unnecessary and inconsistent with the stated intent of the reforms.</li></ul>&nbsp;<h2>Checking the Balance</h2>Members in the news&nbsp;Bank of America Community Development Banking (CDB) <a href="https://newsroom.bankofamerica.com/content/newsroom/press-releases/2022/02/bank-of-america-community-development-banking-provides-record--6.html">provided</a> $6.6 billion in loans, tax credit equity investments, and other real estate development solutions in 2021, resulting in more than 11,600 affordable housing units across the country. This was the fifth consecutive record year of financing, representing a total of $26.6 billion and 60,000 affordable housing units, making a meaningful impact in the firm’s effort to create safe, strong communities. CDB works to help create affordable housing for individuals, families, seniors, veterans, the formerly homeless, and those with special needs. .For the 15th consecutive year, BNY Mellon has&nbsp;<a href="https://www.bnymellon.com/us/en/about-us/newsroom/company-news/bny-mellon-recognized-for-championing-a-culture-of-inclusion-and-equity.html">received</a>&nbsp;a score of 100 on the Human Rights Campaign Foundation’s 2022 Corporate Equality Index, the nation’s foremost benchmarking survey and report measuring corporate policies and practices related to LGBTQ+ workplace equality. BNY Mellon’s efforts and achievements also earned the designation as one of the&nbsp;<a href="https://urldefense.com/v3/__https:/www.hrc.org/resources/best-places-to-work-for-lgbtq-equality-2022__;!!OiWDNh-9Pw!olhtljFfXx5BofJRCgpey60fT96wNt-UZ3R-CB26nGPw2u-ZNVYnvd0fubqh0bk7oPs$">Best Places to Work for LGBTQ+ Equality</a>.Citi <a href="https://news.bloomberglaw.com/banking-law/citi-says-it-exceeded-goals-for-boosting-management-diversity">announced</a> that it met and exceeded its firm-wide, aspirational representation goals,&nbsp;increasing the percentage of women and Black executives at the firm. Citi set these targets in 2018 and said it will weigh future goals and publish new targets later this year.&nbsp;Goldman Sachs&nbsp;One Million Black Women&nbsp;and Grameen America&nbsp;<a href="https://www.goldmansachs.com/media-relations/press-releases/2022/ombw-announcement-20-jan-2022.html">announced</a>&nbsp;a new partnership to advance financial access and inclusion for low-income Black women entrepreneurs. Goldman Sachs will provide $20 million to accelerate Grameen America’s new racial equity initiative,&nbsp;<a href="https://www.prnewswire.com/news-releases/grameen-america-accelerates-efforts-to-achieve-racial-equity-with-goal-to-invest-1-3-billion-in-loans-to-80-000-black-women-entrepreneurs-over-10-years-301290257.html?tc=eml_cleartime">Elevating Black Women Entrepreneurs</a>, to bring affordable credit and capital to financially underserved Black women across the United States.JPMorgan Chase was&nbsp;<a href="https://www.bloomberg.com/company/press/bloombergs-2021-gender-equality-index-reveals-increased-disclosure-as-companies-reinforce-commitment-to-inclusive-workplaces/">named</a>&nbsp;to Bloomberg’s 2021 Gender-Equality Index (GEI). The GEI brings transparency to gender-related practices and policies, including initiatives aimed at closing gender and racial gaps, creating flexible work environments and fostering a culture of inclusion.&nbsp;Morgan Stanley&nbsp;<a href="https://www.morganstanley.com/press-releases/equity-in-education-and-career-outcomes-">announced</a>&nbsp;the launch of the&nbsp;<a href="https://cts.businesswire.com/ct/CT?id=smartlink&amp;url=https%3A%2F%2Fwww.morganstanley.com%2Finstitute-for-inclusion&amp;esheet=52553555&amp;newsitemid=20211220005596&amp;lan=en-US&amp;anchor=Institute+for+Inclusion&amp;index=1&amp;md5=8a73682be4bd291a2e891ec794d46254">Institute for Inclusion</a>’s Equity in Education and Career Consortium.&nbsp;Through collaboration with partner organizations, this initiative will support high school and college students in achieving stronger career and financial outcomes. Funded by an initial commitment of $20 million, this initiative will help address systemic inequities for young adults from low- to moderate-income backgrounds with a focus on ethnically diverse students.State Street&nbsp;<a href="https://clicktime.symantec.com/3GYRhgMZj1AaQx2D5uegiAT6xU?u=https%3A%2F%2Fnewsroom.statestreet.com%2Fpress-releases%2Fpress-release-details%2F2022%2FState-Street-Partners-with-Black-Owned-Businesses-to-Underwrite-1.5-Billion-of-Senior-Unsecured-Debt%2Fdefault.aspx">announced</a>&nbsp;that it is partnering with Black-owned investment firms to underwrite $1.5 billion of senior unsecured debt. This action reinforces the firm’s strong commitment to strengthening Black-owned businesses and represents an ongoing effort by State Street to partner with Black and Latinx-owned investment firms, as well as firms owned by other underrepresented groups, as part of its debt offerings. The move complements a number of efforts within the firm’s&nbsp;<a href="https://clicktime.symantec.com/3H1yRmJer23Hea69drBUjXJ6xU?u=https%3A%2F%2Fwww.statestreet.com%2Fvalues%2Finclusion-diversity%2F10-actions-to-address-racism-and-inequality.html">10 Actions to Address Racism and Inequality</a>.Wells&nbsp;Fargo&nbsp;<a href="https://newsroom.wf.com/English/news-releases/news-release-details/2022/Wells-Fargo-Donates-20-Million-to-Strengthen-Small-Businesses-in-Atlanta-/default.aspx">announced</a>&nbsp;a number of grants in early 2022 from its&nbsp;<a href="https://stories.wf.com/meaningful-investments-and-support-keep-small-business-doors-open">Open for Business Fund</a>, a roughly $420 million&nbsp;fund that the company created in July 2020 to support small businesses during the pandemic. In February, $20 million was provided to The Miami Foundation to help historically disadvantaged small business owners own more of their businesses’ assets and improve technology to better serve customers. In addition, a $20&nbsp;million donation was provided to the United Way of Greater Atlanta, in collaboration with Invest Atlanta, which will distribute the funding as a mix of grants and loans in the city, with a focus on Black-owned and other diverse-owned businesses. The Open for Business fund has also made grants in&nbsp;<a href="https://newsroom.wf.com/English/news-releases/news-release-details/2022/Wells-Fargo-Donates-20-Million-to-Strengthen-Small-Businesses-in-Houston-/default.aspx">Houston</a>,&nbsp;<a href="https://newsroom.wf.com/English/news-releases/news-release-details/2022/Wells-Fargo-Donates-20-Million-to-Strengthen-Small-Businesses-in-Los-Angeles-/default.aspx">Los Angeles</a>, and&nbsp;<a href="https://newsroom.wf.com/English/news-releases/news-release-details/2021/Wells-Fargo-Donates-20-Million-to-Strengthen-Small-Businesses-in-Charlotte-/default.aspx">Charlotte</a>.

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The Forum File, 2022 Edition #1

The Regulatory Reality

Letters

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We advocate for sound policies that recognize the importance of ensuring that banks are able to support the economy, compete internationally, and remain strong. In particular, the Forum supports a review of the GSIB surcharge, a capital requirement that was agreed to internationally, but that U.S. regulators have implemented in a manner that places higher requirements on U.S. banks than that required of foreign competitors. 

The Forum has also weighed in on an international assessment of post-crisis reforms and the clear need to differentiate between jurisdictions and to acknowledge the progress made in the United States.


Capital and Financial Stability

Comment Letter on FRB CBDC Discussion Paper

Article

Empower

External Link

The Empower Role Model List

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<ul><li>BNY Mellon&nbsp;started the <a href="https://www.bnymellon.com/us/en/about-us/diversity-inclusion.html">IMPACT</a> network to help cultivate a diverse and inclusive workplace by promoting the recruitment, retention, professional development and advancement of multicultural employees.</li><li>Morgan Stanley&nbsp;has established an ‘<a href="https://www.morganstanley.com/articles/diversity-hiring-black-banking-professionals">Experienced Professionals Program</a>’ to recruit Black professionals with two or more years of post-graduate or work experience for full-time positions to help expand the talent pool of Black financial professionals.</li><li>State Street&nbsp;helps create a diverse workforce through its <a href="https://www.statestreet.com/values/social-consciousness.html">Global Inclusion program</a>, which offers mentoring, events and performance goals focused on diversity and inclusion, and employee networks.</li></ul>

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Diverse Talent

We are building a pipeline of diverse talent by expanding the pool of diverse managers and ensuring an inclusive workplace.

<ul><li>Bank of America&nbsp;has a Global Diversity &amp; Inclusion Council chaired by CEO Brian Moynihan, which leads D&amp;I efforts and works with the management team setting related goals for the company.</li><li>Citi&nbsp;has named members of the CEO’s leadership team as co-chairs of its affinity groups, which set and reinforce the company’s diversity priorities and goals.</li><li>JPMorgan Chase&nbsp;<a href="https://www.jpmorganchase.com/news-stories/jpmc-announces-brian-lamb-as-global-head-of-diversity-inclusion">named</a> a new Global Head of Diversity &amp; Inclusion in April 2020, a newly created position that reports directly to the firm’s co-presidents.</li><li>Wells Fargo has created a new expanded diversity role reporting directly to the CEO, with a broad mandate to drive diversity and inclusion in both the firm’s workplace and business.</li></ul>

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Leadership Roles

Our institutions are establishing and empowering Diversity & Inclusion leadership roles dedicated to advancing diversity, inclusion and equity in the workplace in partnership with chief executives.

<ul><li>Bank of America&nbsp;offers Employee Networks that provide teammates from diverse backgrounds opportunities to connect with each other, develop leadership skills, and build strong ties with the communities they serve.</li><li>JPMorgan Chase&nbsp;has multiple <a href="https://careers.jpmorgan.com/us/en/about-us/diversity">Business Resource Groups</a> (BRGs) that help foster networks of employees and connect women and minority employees with each other to provide mutual support and sharing.</li><li>Morgan Stanley&nbsp;has multiple <a href="https://www.morganstanley.com/people-opportunities/enetworking">Employee Networks</a> designed to enhance employee engagement, deliver substantive content, create a framework for cross-business unit connectivity and idea-sharing, and advance the firm’s overall culture of inclusion.</li></ul>

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Employee Resource Groups

We have launched and expanded our Employee Resource Groups (ERGs) and other affinity groups to support employees and create conditions for them to succeed.

<ul><li>Bank of America&nbsp;has created unconscious bias trainings and offers diversity &amp; inclusion training.</li><li>Citi trains all hiring managers and Human Resources employees on unconscious bias.&nbsp;</li><li>JPMorgan Chase&nbsp;requires all employees to participate in unconscious bias and diversity &amp; inclusion training.</li><li>Wells Fargo&nbsp;requires live anti-racism manager training and has developed a series of educational sessions in which employees can share with their colleagues their personal stories and perspectives on the realities of racism in the U.S.</li></ul>

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Employee Trainings

We are creating and offering training focused on concepts like anti-racism, unconscious bias, and social justice.

<ul><li>Bank of America&nbsp;has committed to hiring 10,000 individuals from low- and moderate-income communities by 2023.</li><li>Citi has set a goal of having 30% Black and Hispanic/Latinx colleagues in its U.S. analyst and associate programs.</li><li>Goldman Sachs&nbsp;<a href="https://www.goldmansachs.com/media-relations/press-releases/current/update-on-inclusion-and-diversity.html">announced</a> a plan to, by 2025, achieve a representation among its vice presidents that equates to 40 percent women globally, 7 percent Black professionals in the Americas and UK, and 9 percent Hispanic/Latinx professionals in the Americas.</li><li>JPMorgan Chase&nbsp;has committed to hiring 4,000 Black students in full-time positions, apprenticeships and internships over the next five years.</li><li>State Street&nbsp;has <a href="https://www.statestreet.com/values/inclusion-diversity/diversity-goals.html">set</a> three- and five-year goals for achieving higher percentages of employees of color in SVP, MD, and VP positions across the firm.</li><li>Wells Fargo&nbsp;has committed to doubling the number of Black employees in leadership positions over the next five years.</li></ul>

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Hiring Commitments 

Our institutions have established hiring commitments to diversify our workforces.

**Our commitment to diversity, equity and inclusion**

Promoting Diversity, Equity and Inclusion

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The Goldman Sachs Group, Inc.

David Solomon is Chairman and Chief Executive Officer and a member of the Board of Directors of The Goldman Sachs Group, Inc.

Previously, he was President and Chief Operating Officer and prior to that, he served as Co-Head of the Investment Banking Division from 2006 to 2016. Before that, Mr. Solomon was Global Head of the Financing Group, which includes all capital markets and derivative products for the firm’s corporate clients. He joined Goldman Sachs as a Partner in 1999.

Mr. Solomon is a member of the Board of Trustees of Hamilton College and serves on the board of The Robin Hood Foundation.

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David Solomon

The Goldman Sachs Group, Inc. Chairman and Chief Executive Officer, Forum Chairman

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State Street Corporation

Ron is chairman and chief executive officer of State Street Corporation. He is also a member of State Street Corporation’s Board of Directors.

Ron was previously president and chief operating officer of State Street Corporation, and before that president and chief executive officer of State Street Global Advisors, the investment management arm of State Street Corporation. He joined State Street in 2015.

Prior to State Street, Ron was president of Asset Management & Corporate Services for Fidelity Investments, responsible for all Fidelity asset management organizations and Fidelity’s corporate functions and enterprise technology. He served at Fidelity from 2010 to 2014.

Prior to joining Fidelity, Ron served as president and chief executive officer of BNY Mellon Asset Management in Boston, a position to which he was named in 2007. During this time, he also served as vice chairman of Bank of New York Mellon Corporation and was a member of its Executive Committee. Additionally, Ron oversaw all of Bank of New York Mellon’s activities in Asia. Prior to the 2007 merger of Bank of New York and Mellon, he was vice chairman of Mellon Financial Corporation and president and chief executive officer of Mellon Asset Management. He served at Mellon and Bank of New York Mellon from 1997 to 2010.

Prior to Mellon, Ron was with McKinsey & Company, Inc., from 1986 to 1997 and was elected a partner in 1992. He founded the Investment Management practice worldwide and was co-founder and co-leader of the firm’s North American Personal Financial Services practice. Additionally, he was a member of the Worldwide Property & Casualty Insurance practice. During his tenure with McKinsey, Ron served in the firm’s Boston, New York, and Stockholm offices.

Ron received his Bachelor of Arts degree in political science from Syracuse University in 1980 and his Master of Business Administration from Harvard Business School in 1986.

Ron serves on the boards of Unum Corp. and Rhode Island Commerce Corporation. He also serves on the boards of Beth Israel Lahey Health, The Boston Foundation, IYRS School of Technology and Trades, Syracuse University and WBUR. Ron’s philanthropic and civic interests include corporate governance, retirement/healthcare policy and funding, education, and climate. He has led several initiatives on gender equality. Ron is a frequent speaker and writer, and an avid offshore sailboat racer.

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Ronald O'Hanley

State Street Corporation Chairman And Chief Executive Officer, Forum Vice Chairman

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Bank Of America

Brian Moynihan leads a team of more than 200,000 employees dedicated to making financial lives better for people, companies of every size, and institutional investors across the United States and around the world.

Bank of America is recognized as a top employer by Working Mother magazine and Military Times. The company is also listed on Fortune magazine’s list of the Best Workplaces for Diversity and the Best Workplaces for Parents. It was also named one of the Best Places to Work for Disability Inclusion by the U.S. Business Leadership Network and the American Association of People with Disabilities. In 2018, Euromoney recognized Bank of America as the World’s Best Bank and the World’s Best Bank for Diversity and Inclusion, as part of their annual Global Awards for Excellence. Bank of America was also named the 2019 Catalyst Award winner, honored for supporting the continued development, empowerment and advancement of women in the company and around the world.

Moynihan participates in several organizations that focus on economic and market trends, including the World Economic Forum International Business Council, the Financial Services Forum, the Bank Policy Institute (chair), the Business Roundtable, and the American Heart Association CEO Roundtable (co-chair). He is also a member of the Federal Advisory Council of the Federal Reserve Board.

Moynihan leads the company’s Global Diversity and Inclusion Council and is a member of the museum council for the Smithsonian’s National Museum of African American History and Culture. Moynihan is also a member of the Brown University Corporation’s Board of Fellows and the Congressional Medal of Honor Foundation Board.

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Brian Moynihan

Bank Of America Chairman Of The Board And Chief Executive Officer

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BNY Mellon

Todd Gibbons currently serves as the Chief Executive Officer of BNY Mellon. Prior to that, Todd had been a Vice Chairman of BNY Mellon and CEO of Clearing, Markets and Client Management. In that role he oversaw the Pershing clearing business; the trading, financing, collateral and liquidity management solutions delivered through the Markets business; treasury services and commercial payment activities; the U.S. government securities clearance and U.S. tri-party repo businesses delivered through BNY Mellon Government Securities Services Corp; credit services; global client management; and regional area management. From 2008 through 2017, he served as CFO. Previously, for six years he was Chief Risk Policy Officer, overseeing credit, operational and market risk management of the company and The Bank of New York.

Todd also served as CFO of The Bank of New York for almost a year prior to the merger. He first joined The Bank of New York in 1986 and held top management positions in the capital markets business, including head of global treasury, with responsibility for asset and liability management, funding, money market trading, swaps and derivative products. Prior to joining The Bank of New York, he was assistant treasurer at Handy and Harman, a leading refiner, processor and fabricator of precious metals.

Todd is a member of BNY Mellon’s Executive Committee. He also serves on the advisory board of Wake Forest University’s Business School. He holds a B.S. in Business Administration from Wake Forest University and an MBA from Pace University.

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Thomas Gibbons

BNY Mellon Chief Executive Officer

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Citigroup

Jane Fraser is the Chief Executive Officer of Citi, the world’s most global bank, serving millions of consumers, businesses and institutions across 160 countries and jurisdictions. She is the first female CEO in the firm’s history.

Jane has deep experience across Citi’s consumer and institutional businesses and, in many ways, she helped shape Citi into the company it is today. Before becoming CEO in February 2021, she was President of Citi and CEO of the Global Consumer Bank, responsible for all of Citi’s Consumer businesses, including Retail Banking and Wealth Management, Credit Cards, Mortgage and Operations and Technology in 19 markets.

Before that, she was the Chief Executive Officer of Citigroup Latin America from 2015 to 2019. From 2013 to 2015, she was the Chief Executive Officer of the U.S. Consumer and Commercial Banking and CitiMortgage. From 2009 to 2013, Jane served as the Chief Executive Officer of Citi’s Global Private Bank. Prior, Jane was the Global Head of Strategy and Mergers & Acquisitions for Citi from 2007 to 2009. She joined Citi in 2004 in the Corporate and Investment Banking division.

Before joining Citi, Jane was a Partner at McKinsey & Company. She started her career at Goldman Sachs in the Mergers & Acquisitions department in London and then worked for Asesores Bursátiles in Madrid, Spain.

She is Vice Chair for Partnership for New York City and a member of the Harvard Business School’s Board of Dean’s Advisors, the Stanford Global Advisory Board, the Economic Club of New York and the Council on Foreign Relations. Jane has an M.B.A. from Harvard Business School and an M.A. in economics from Cambridge University. She is married with two children.

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Jane Fraser

Citigroup Chief Executive Officer

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JPMorgan Chase & Co.

Jamie Dimon is Chairman of the Board and Chief Executive Officer of JPMorgan Chase & Co., a global financial services firm with assets of $2.5 trillion and operations worldwide. The firm is a leader in investment banking, financial services for consumers, small business, commercial banking, financial transaction processing and asset management.

Dimon became CEO on January 1, 2006 and one year later also became Chairman of the Board.  He was named President and Chief Operating Officer upon the company’s merger with Bank One Corporation on July 1, 2004. Dimon joined Bank One as Chairman and CEO in 2000.

Dimon began his career at American Express Company.  Next, he served as Chief Financial Officer and then President at Commercial Credit, which made numerous acquisitions and divestitures, including acquiring Primerica Corporation in 1987 and The Travelers Corporation in 1993. Dimon served as President and Chief Operating Officer of Travelers from 1990 through 1998 while concurrently serving as Chief Operating Officer of its Smith Barney Inc. subsidiary before becoming co-Chairman and Co-CEO of the combined brokerage following the 1997 merger of Smith Barney and Salomon Brothers.  In 1998, Dimon was named President of Citigroup Inc., the global financial services company formed by the combination of Travelers Group and Citicorp.

Dimon earned his bachelors degree from Tufts University and holds an MBA from Harvard Business School. He serves on the boards of directors of a number of non-profit institutions including the Clearing House and Harvard Business School. Additionally, he is the Chairman of the Business Roundtable and serves on the executive committee of the Business Council and the Partnership for New York City, and is a member of the Financial Services Forum, Financial Services Roundtable and Council on Foreign Relations.

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Jamie Dimon

JPMorgan Chase & Co. Chairman And Chief Executive Officer

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Morgan Stanley

Mr. Gorman is Chairman and CEO of Morgan Stanley.

Mr. Gorman became CEO in January 2010 and Chairman in January 2012. He joined the Firm in February 2006 and was named Co-President in December 2007.

Before joining Morgan Stanley, Mr. Gorman held a succession of executive positions at Merrill Lynch. Prior to this, he was a senior partner of McKinsey & Co. and began his career as an attorney in Melbourne, Australia.

Among his civic activities, Mr. Gorman serves as a Director of the Federal Reserve Bank of New York and the Council on Foreign Relations, and is a member of the Board of Overseers of the Columbia Business School, the Monetary Authority of Singapore International Advisory Panel, the Business Council, and the Board of the Institute of International Finance.

He formerly served as President of the Federal Advisory Council to the U.S. Federal Reserve Board, Co-Chairman of the Partnership for New York City, Chairman of the Board of the Securities Industry and Financial Markets Association and Co-Chairman of the Business Committee of the Metropolitan Museum of Art.

Mr. Gorman, who was born in Australia, earned a B.A. and Law degree from the University of Melbourne and an M.B.A. from Columbia University.

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James Gorman

Morgan Stanley Chairman And Chief Executive Officer

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Wells Fargo & Company

Charles W. Scharf is chief executive officer and president, and a member of the Board of Directors of Wells Fargo & Company.

A financial services veteran with 24 years of experience in leadership roles in the banking and payments industries, Charlie served as chief executive officer of Bank of New York Mellon from July 2017 to October 2019 and the chairman of its board from January 2018 to October 2018. He also was chief executive officer and a director of Visa Inc. from October 2012 to December 2016.

During his tenure at Bank of New York Mellon, Charlie demonstrated a strong track record in initiating and leading change, driving results, strengthening operational risk and compliance, and innovating amid a rapidly evolving digital landscape.

As the CEO of Visa, Charlie transformed the firm into a technology-driven digital commerce company by partnering with the world’s leading technology companies to drive new payment experiences and introduce new technologies to improve payment system security.

Previously, he was a managing director of One Equity Partners at JPMorgan Chase & Co. and chief executive officer of Retail Financial Services at JPMorgan Chase. He also was chief executive officer of the retail division of Bank One Corp., chief financial officer of Bank One Corp., chief financial officer of the Global Corporate and Investment Bank division of Citigroup, and chief financial officer of Salomon Smith Barney and its predecessor company.

Charlie earned a Bachelor of Arts degree from Johns Hopkins University and an MBA from New York University.

He is a director of Microsoft Corporation, serves on the board of trustees of Johns Hopkins University, is a member of The Business Council, and is chairman of the New York City Ballet. He lives in New York City.

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Charles Scharf

Wells Fargo & Company Chief Executive Officer And President

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We are the eight largest and most diversified financial institutions headquartered in the United States. Our more than 750,000 U.S. employees&nbsp;serve millions of consumers, businesses, investors, and communities across the country.

Forum members increased credit to businesses and households by 11% to $9.2 trillion in 2021.

Forum members recognize that climate change poses risks to the world’s economy.
The transition to a low-carbon economy will occur over several decades and requires collaboration between a wide range of industries and government. The Forum advocates for appropriate policies and international cooperation to ensure that climate policies and regulations related to the financial industry are based on science, risk, and sound methodologies.


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