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.