The Global Financial Markets Association (GFMA), which is an alliance between SIFMA, ASIFMA, and AFME, provides comments to the Financial Stability Board (FSB) on a FSB background note entitled, Shadow Banking: Scoping the Issues. GFMA provides comments on this FSB note issued on April 12 which sets out the current thinking of the FSB task force to develop initial recommendations to strengthen the oversight and regulation of the shadow banking system. GFMA supports the FSB’s view that a single regulatory approach for all non-banking activities is unlikely to be effective; differentiation is necessary to account for different business models, risk characteristics, and contribution to systemic risk. Significant changes to bank prudential requirements in Basel III could lead to a need for increased non-bank funding to complement funding provided by banks. We support the FSB’s view that a single regulatory approach for all non-banking activities is unlikely to be effective and differentiation is necessary to adjust for various business models.  In particular, we support the promotion of increased transparency of unregulated activities through reporting and disclosure to the relevant authorities rather than other additional regulation.