Date: September 3, 2014
Issue: Financial Stability Oversight Council
To: Department of the Treasury
Filing Type: Regulatory
Description: We are writing to you, in your capacity as Chair of the Financial Stability Oversight Council (“FSOC”), to express our appreciation for the FSOC’s apparent shift in focus of its ongoing review of the asset management industry. We are encouraged that FSOC has turned away from the Section 113 systemically important financial institution (“SIFI”) designation process, which is inappropriate for asset management and plagued by procedural and substantive flaws, and instead has proposed proceeding with more risk-based analysis of specific products and activities. We caution FSOC to proceed with this analysis in a rigorous, objective and transparent manner. Recalling that its mandate is the stability of the entire financial system, we also encourage FSOC to embrace this approach in its analyses of all nonbank financial industries and to look beyond individual industries to activities that may generate systemic risk. We recommend that the FSOC forego further nonbank designations pending such reviews.