SIFMA AMG Comments on FSOC Nonbank SIFI Designation Guidance

Washington, D.C., November 4, 2023 – SIFMA’s Asset Management Group (SIFMA AMG) today issued the following comment regarding changes to guidance on nonbank financial company designations as proposed by the Financial Stability Oversight Council (FSOC):

“FSOC’s decision today to finalize its interpretive guidance and risk framework is disappointing.  As we explained in our comment letter, the changes proposed are entirely unnecessary for many nonbank financial companies, like asset managers, which are already subject to stringent federal oversight by the SEC and have shown consistent resilience in times of economic stress. SIFMA AMG has long supported FSOC’s activities-based approach in identifying and addressing systemic risk, as this approach reduces the potential for competitive distortions among companies and in markets that could arise from entity-specific regulation and supervision. As acknowledged by the FSOC in its 2019 guidance, an activities-based approach also better ensures that FSOC may ‘identify and address the sources of risk to financial stability on a system-wide basis, rather than addressing risks only at a particular nonbank financial company that may be designated.’ We are closely examining the details of today’s release, and we continue to urge FSOC to only consider entity-based designations as a last resort.”


SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit

SIFMA’s Asset Management Group (SIFMA AMG) brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms – both independent and broker-dealer affiliated – whose combined assets under management exceed $62 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.