SIFMA Advocacy Book
The SIFMA Advocacy Book (dated April 2013) provides a macro-level snapshot of SIFMA’s positions on key issues facing financial regulators and policymakers.
While issues and positions will likely evolve with policy proposals and additional analysis, we believe this guide provides an overview of the many critical decisions regulators will be making in the coming months and how they will impact our markets and our economy for years to come.
SIFMA has supported responsible regulatory reform from the start, and we remain committed to being productive participants in the process. Through our committees, made up of more than 6,000 industry experts, we provide information and analysis to help regulators craft rules that work, without frustrating economic growth. It is the same information that has informed these positions.
Excerpt
Introduction
The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) was signed into law by President Obama on July 21, 2010. Now, we are in the midst of a rulemaking process that is designed to ensure a broad range of issues and detailed expertise – industry, economic, scientific and consumer – are incorporated at various stages. The end goal of this process is to ensure that final regulations are balanced, consistent with the intent of the initial legislation, and avoid any potential unintended consequences.
SIFMA continues to support measures to restore faith and confidence in our financial system, mitigate systemic risks and prevent another crisis. However, SIFMA remains concerned with sequencing of Dodd-Frank Act implementation and the lack of coordination among U.S. regulators, which we fear could lead to conflicting rules, fragmentation across markets, and extended uncertainty for market participants. Compounding the problem, the cross-border application of some promulgated rules requires international regulatory coordination, even as the U.S., EU and Asia move in different directions on financial reform.
Banking and securities markets are critical to economic growth. SIFMA believes Dodd-Frank Act implementation issues need to be addressed and a strong coordinating mechanism must be created. The Dodd-Frank Act mandates that the Financial Stability Oversight Council (FSOC) be the coordinating body for financial reform and, as such, we believe FSOC should begin a comprehensive review of all proposed and finalized rules, set regulatory priorities and re-sequence the implementation of new regulations.
To help with this process, SIFMA commissioned three papers from Karen Shaw Petrou, Managing Partner at Federal Financial Analytics, to help identify conflicts, unintended consequences, and impediments to the effective implementation of Dodd-Frank Act mandated regulations.