Recommendations Regarding the Presidential Memorandum for the Secretary of the Treasury
Summary
SIFMA AMG provided recommendations to the U.S. Department of the Treasury as it develops the report required under the Presidential Memorandum relating to the Financial Stability Oversight Council.
We strongly support Treasury’s thorough review of the FSOC and its nonbank designation process under provisions of the Dodd-Frank Act. During the past several years, we have been actively involved in numerous matters relating to prudential regulation of asset management activities and the potential designation of asset management firms as nonbank systemically important financial institutions (“SIFIs”) under provisions of the Dodd-Frank Act.
In our most recent letter to Treasury responding to the February 3 Executive Order, we included an overview of the asset management industry, a discussion of the post-crisis regulation of asset management activities, and a list of recommendations and supporting arguments and materials.
Excerpt
August 18, 2017
The Honorable Steven Mnuchin
United States Treasury Secretary
U.S. Department of the Treasury
1500 Pennsylvania Avenue, N.W.
Washington, DC 20220
Re: Suggested Recommendations Regarding the Presidential Memorandum for the Secretary of the Treasury (April 21, 2017)
Dear Secretary Mnuchin:
The Asset Management Group (“AMG”)1 of the Securities Industry and Financial Markets Association (“SIFMA”) appreciates the opportunity to provide our suggested recommendations to the U.S. Department of the Treasury (“Treasury”) as it develops the report (the “Report”) required under the Presidential Memorandum (“Presidential Memorandum”) relating to the Financial Stability Oversight Council (“FSOC”).2
We strongly support Treasury’s thorough review of the FSOC and its nonbank designation process under provisions of the Dodd-Frank Act. During the past several years, we have been actively involved in numerous matters relating to prudential regulation of asset management activities and the potential designation of asset management firms as nonbank systemically important financial institutions (“SIFIs”) under provisions of the Dodd-Frank Act. Our written letters to FSOC, the U.S. Securities and Exchange Commission (“SEC”), Financial Stability Board (“FSB”), and the International Organization of Securities Commissions (“IOSCO”), among others, present detailed and substantial reasons supporting our concerns about prudential regulation of asset management firms.3 In our most recent letter to Treasury responding to the February 3 Executive Order, we included an overview of the asset management industry, a discussion of the post-crisis regulation of asset management activities, and a list of recommendations and supporting arguments and materials.4 For purposes of brevity, we have not included the lengthy discussions that were set forth in our previous letter (please see Appendix A for a list of prior SIFMA AMG letters)