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Joint trades letter supporting legislation to improve guardrails and transparency in the designation process for systemically important financial institutions (H.R. 3682, the Financial Stability Oversight Council Improvement Act of 2025).
October 29, 2025
IAA and Trades Encourage FSOC to Return to an Activities-Based Approach
Joint trades letter encouraging FSOC to restore the 2019 guidance governing the designation of nonbank financial institutions as SIFIs.
July 14, 2025
Comments on FSOC Guidance Regarding Supervision and Regulation of Nonbank Financial Companies
The IAA supported FSOC’s proposed activities-based approach to identify, assess, and address potential systemic risk in nonbank financial companies. The IAA also argued that the fundamental nature of asset management does not pose systemic risk because it is an agency business, and that asset managers are subject to robust regulation.
May 10, 2019
Comments on Name-Sharing Restrictions of the Volcker Rule
The IAA supported proposed amendments to the Volcker rule to conform to certain statutory amendments, but urged the Volcker Agencies to allow a limited exception on the name-sharing restrictions where the name-sharing is required or expected under local law.
March 11, 2019
Comments on Amendments to Volcker Rule Regulations
The IAA made several recommendations regarding proposed revisions to the Volcker Rule Regulations, including removing the proposed accounting prong of the trading account definition and excluding all regulated funds from the banking entity definition. The IAA also made several comments related to other definitions in the proposal.
October 16, 2018
Comments on OCC’s Implementation of the Volcker Rule Statute
The IAA raised concerns that the Volcker Regulations go beyond the purpose and intent of the Volcker Rule Statute. The IAA also recommended exclusions from certain prohibitions, updates to certain definitions, and eliminating the prohibition on name-sharing in the asset management exemption.
September 21, 2017
The IAA explained that asset managers do not present systemic risk and stress testing is unnecessary for investment advisory firms due to the nature of their business. The IAA also discussed the need to review, modernize, and streamline certain regulations under the Advisers Act, and the need to avoid overlapping regulation by the SEC and CFTC.
August 15, 2017
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