New York Clearing House Association (NYCHA) submits comment letter on merchant banking rules and request to Fed for e-commerce activities

The New York Clearing House Association (NYCHA) comment letter on the Federal Reserve Board's interim rule on merchant banking criticizes the Fed's proposed capital requirement as, among other things, discouraging the use of the merchant banking and other investment authority, placing financial holding companies at a competitive disadvantage, not accomplishing or addressing the Fed's stated reasons for applying the capital rule, and being inconsistent with the Gramm-Leach-Bliley Act. The NYCHA has also requested that the Fed find that certain e-commerce activities are financial in nature.