The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) created the Financial Stability Oversight Council (FSOC), composed of 10 voting members with diverse areas of expertise, to comprehensively monitor and mitigate threats to the U.S. financial system as well as ensure greater coordination among the array of financial regulators. While there was agreement that absent consolidation among the nearly two dozen financial regulators a body like FSOC tasked with assessing risks to the system would be needed, there was little agreement at the time about the best way to ensure systemic risks are identified and mitigated. In the over three years since FSOC’s creation, we believe several fundamental shortcomings in the FSOC’s structure and operations have been exposed.
