Date: April 7, 2014

Issue: Systemic Risk


Filing Type: International

Description: In its current form, the proposed Fund methodology targets U.S. registered funds only, without providing any empirical evidence that U.S registered funds pose a risk to the global financial markets or considering the adequacy of existing U.S. regulation of U.S. registered funds. As such, the Document does not have a global scope and would seemingly be outside of the G-20 remit. In addition, the FSB does not have any binding legal authority to direct U.S. regulatory authorities to take specific actions with respect to a U.S. registered fund that may be designated an NBNI G-SIFI. Accordingly, the GRGI believes that the FSB and IOSCO should withdraw the proposed Fund Methodology.

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