The Dodd-Frank Report Card: Systemic Regulation
March 7, 2012
This is a new world for large bank holding companies and systemically important financial institutions (SIFIs). Designating nonbank financial companies as SIFIs by the Financial Stability Oversight Council (FSOC) has moved forward with the FSOC issuance of a proposed rule and guidance regarding the designation process. The proposed rule leaves a range of issues confronting companies that may be subject to a SIFI designation. At the same time, the Federal Reserve Board is developing a program of enhanced supervision of large bank holding companies and SIFIs. The program will include the following topics:
- Understanding the FSOC’s three-step SIFI designation process
- What are the key issues in regard to the FSOC’s SIFI designation guidance?
- What can potential SIFIs do to reduce the likelihood of being designated or to oppose a designation?
- What will designation mean for a SIFI?
- What are the enhanced prudential standards that will apply to the large bank holding companies and SIFIs?
- How to challenge the SIFI designation process
This program is part of a series - The Dodd-Frank Report Card: The Impact of Dodd-Frank in 2012. Series Chairman: Thomas P. Vartanian, Partner, Dechert LLP.