Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies

Published on:
December 15, 2011

SIFMA provides comments to the Financial Stability Oversight Council (FSOC) on FSOC’s second notice of proposed rulemaking and proposed interpretive guidance regarding the criteria that should inform FSOC’s designation of nonbank financial companies for supervision by the Board of Governors of the Federal Reserve System under Section 113 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act), Docket No. FSOC-2011-0001-0045. The main concerns that SIFMA shares on the proposal include:

  • The uniform quantitative thresholds are overly broad and not clearly specified;
  • There is insufficient clarity on when Stage 2 begins and ends; and
  • Firms should be given sufficient time to provide information to the Council in Stage 3.

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