Subject: File No. S7-08-12
From: Rich Whiting
Affiliation: General Counsel, The Financial Services Roundtable

January 2, 2013

In the attached letter, we request that the Commission extend the deadline for comments on this topic in view of a recent proposal from the Federal Reserve Board that fundamentally will restructure the capital regulations that are applied to the U.S business operations of non-U.S. banks and foreign nonbank financial companies.