Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies (Joint Trades)

Published on:
May 22, 2023
Submitted to:
FSOC
Submitted by:
SIFMA, SIFMA AMG and Other Associations

Summary

SIFMA, SIFMA AMG, and other associations in a joint letter provided comments to the Financial Stability Oversight Council (FSOC) in response to the proposals to revise existing interpretive guidance on nonbank financial company designations and to adopt an analytic framework the Council would employ to assess potential risks to U.S. financial stability.

SIFMA signed with the following:

Alternative Credit Council

Alternative Investment Management Association

American Council of Life Insurers

American Investment Council

American Property Casualty Insurance Association

Asset Management Group of the Securities Industry and Financial Markets Association

Financial Technology Association

Finseca

Investment Company Institute

Loan Syndications and Trading Association

Managed Funds Association

Mortgage Bankers Association

Nareit

National Association of Mutual Insurance Companies

Securities Industry and Financial Markets Association

U.S. Chamber of Commerce

Excerpt

The Honorable Janet L. Yellen

Secretary of the Treasury

Department of the Treasury

1500 Pennsylvania Avenue, NW

Washington, DC 20220

Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies (RIN 4030-[XXXX]) (88 Fed. Reg. 26,234-26,244, April 28, 2023)

Analytic Framework for Financial Stability Risk Identification, Assessment, and Response (RIN 4030-[XXXX]) (88 Fed. Reg. 26,305-26,311, April 28, 2023)

Dear Secretary Yellen:

The undersigned associations are writing in response to the Financial Stability Oversight Council’s (“FSOC” or “the Council”) proposals to revise existing interpretive guidance on nonbank financial company designations (“Nonbank Guidance”) and to adopt an analytic framework the Council would employ to assess potential risks to U.S. financial stability (“Analytic Framework”) (together the “Proposals”). We respectfully request that the Council extend the comment period for each proposal for at least an additional 30 days.

While the Nonbank Guidance and Analytic Framework were released by the FSOC as two separate proposals, they are intrinsically interlinked. The 60-day open comment period for the Proposals is not sufficient time for our wide array of members to fully evaluate the impact of the substantial amendments to the Nonbank Guidance and the expansive new risk areas under consideration by the Council in the new Analytic Framework. Moreover, since the Proposals open a wide array of new industries and activities to designation as a systemically important financial institution (SIFI), entities require more than 60 days to assess their potential inclusion, for the first time, in a nonbank review process.

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