SIFMA’s Asset Management Group (SIFMA AMG) provides comments to the U.S. Securities and Exchange Commission (SEC) on Asset Management Fund Stress Testing Rulemaking.

SIFMA AMG recognizes that the SEC has the responsibility to draft such a rulemaking in accordance with Section 165(i)(2)(A) of the Dodd-Frank Act. AMG believes that any rulemaking should be principles-based, given the unique characteristics of funds and the asset management industry generally. The SEC should also recognize that stress testing is only one part of an effective and coherent risk management process for asset managers. Therefore, the objective of the stress testing is not to test for solvency or capital adequacy, but to complement other approaches in assessing investment risk.

See also: Section 165(i)(2)(A) of the Dodd-Frank Act