Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
On June 6, 2024, the US Department of the Treasury (Treasury) issued a request for information (RFI) on the “uses, opportunities and risks of artificial intelligence (AI) in the financial services sector.” The RFI seeks...more
The Financial Stability Oversight Council unanimously approved an analytic framework for financial stability risk identification, assessment and response and interpretive guidance on nonbank financial company determinations...more
A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk...more
FDIC Board Governance Dispute on Review of Bank Mergers Aired Publicly - CFPB Director Rohit Chopra on December 9 published on the CFPB’s website a blog post captioned “How Should Regulators Review Bank Mergers?” in...more
On November 1, 2021, the President’s Working Group on Financial Markets (PWG) - along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) - published the Report on...more
There are less than two months before world leaders meet in Glasgow for the UN-sponsored Climate Change summit known as the Conference of the Parties (COP 26). This summer, we have been inundated with dire reports about...more
The National Association of Insurance Commissioners (NAIC) held its 2019 Spring National Meeting from April 5 through 9 in Orlando, Florida. This meeting was distinguished by a very large class of new commissioners (15 in...more
In a response to the difficulties it experienced in identifying nonbank systemically important entities, the Financial Stability Oversight Council (FSOC) has proposed a new procedure for detecting and dealing with potential...more
As required by President Trump’s Executive Order 13772, the U.S. Department of the Treasury issued a report, “A Financial System That Creates Economic Opportunities, Asset Management and Insurance,” addressing the regulatory...more
On April 18, 2016, the Financial Stability Oversight Council again warned that asset managers present systemic risk to financial stability in five key areas: ..liquidity and redemptions; ..leverage; ..operational...more
On September 22, 2015, the Securities and Exchange Commission (“SEC”) proposed a new rule and amendments to rules and reporting forms under the Investment Company Act of 1940 (the “1940 Act”), designed to standardize...more
The Board of the International Organization of Securities Commissions (IOSCO) in June made an important recommendation concerning any risks that investment funds and advisors present to the global financial system....more
In seeking comment on potential risks to the U.S. financial system created by asset managers, the Financial Stability Oversight Council (FSOC) again places asset managers in its crosshairs. This crusade potentially can lead...more
The Financial Stability Oversight Council (“FSOC”) has taken the next step in its consideration of the asset management industry, by issuing a notice requesting public comment on whether asset management products and...more
The Financial Stability Oversight Council, or FSOC, voted on December 18, 2014 to release a notice seeking public comment regarding potential risks to U.S. financial stability from asset management products and activities,...more
The proposal is consistent with international recommendations and Basel III criteria. On March 12, the Securities and Exchange Commission (SEC) proposed new rules and rule amendments (the Proposal) that would enhance...more