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