FSOC Issues New Proposed SIFI Designation Rule

October 19, 2011
The Financial Stability Oversight Council (“FSOC”) recently issued a second notice of proposed rulemaking regarding its process for designating a nonbank financial company as a systemically important financial institution (“SIFI”) under the Dodd-Frank Act. After designation, a SIFI would be subject to heightened prudential standards as well as supervision and enforcement action by the Federal Reserve Board. This update analyzes the second notice, which provides new quantitative guidance to nonbank financial companies regarding their potential status at the initial stage of review.