The FSOC’s Annual Report Suggests Potential Paths Forward

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The recently issued annual report of the Financial Stability Oversight Council (“FSOC” or “Council”) indicates that the members continue to review the major unfinished business of financial regulatory reform and ramp up the process by which they determine where to focus their collective efforts going forward. While progress has been slow, the financial industry should monitor the Council’s activities to see where new hot buttons might emerge, and ideally have some input while the efforts continue.

The FSOC’s 2013 annual report may be most notable for what it is missing. On two of the most significant issues facing the FSOC, the report was silent: it did not include an announcement of the designation of any nonbank financial companies (“SIFIs”) as systemically important, nor did it include the announcement of any further progress on money market mutual fund reform (“MMF”).

So, the questions remain: what will the Council focus on once Secretary Lew has settled in as Chairperson, the work of SIFI designations is complete, and MMF reforms have been proposed by the SEC, and how could these issues affect market participants?

Please see full memo below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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