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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
In his first remarks to the Financial Stability Oversight Council (FSOC) since becoming SEC Chair, Gary Gensler reiterated his agency’s focus on enhancing the resiliency of money market funds. Gensler...
June 15, 2021
FSOC Meeting Focuses on Hedge Funds, Mutual Funds, Impact of Climate Change on Financial Stability
The Financial Stability Oversight Council’s (FSOC’s) first meeting of the year – and of the new Administration – focused on hedge funds, mutual funds, and climate change. Following a discussion...
April 09, 2021
Sen. Warren Questions Treasury’s Yellen about SIFI Designations for Asset Managers
During a recent Senate Banking Committee hearing, Sen. Elizabeth Warren (D-Mass.) pressed Treasury Secretary Janet Yellen on whether large asset managers should be designated as “systemically important financial institutions,” or...
March 26, 2021
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