The Asset Management Group (the “AMG”) of the Securities Industry and Financial Markets Association (“SIFMA”) and the Investment Adviser Association (the “IAA”) appreciate the opportunity to respond to the Notice Seeking Comment on Asset Management Products and Activities (the “Notice”) published by the Financial Stability Oversight Council (the “Council”). The members of the SIFMA AMG and the IAA are primarily U.S.-based asset management firms. The response will focus on the operation, structure, and controls of the products and services offered by our member firms as they relate to the Council’s consideration of potential risks to the U.S. financial system.

In the letter, the Associations demonstrate how asset managers and the funds they manage do not present systemic risk. The Associations call on FSOC to pause and allow the Securities and Exchange Commission (SEC), as the primary regulator of the industry, to complete its own review of asset manager products and activities and consider the cumulative impact of any new rules before taking any action.

See Also:
Press Release: SIFMA AMG and IAA Demonstrate that the Asset Management Industry Does Not Present Systemic Risk, Urge Deference to SEC in Comments to FSOC
FSOC Notice Seeking Comment on Asset Management Products and Activities