IAA Statement on FSOC’s Proposed Return to An Activities-Based Approach
May 14, 2026
The IAA strongly supports the Financial Stability Oversight Council’s proposal to revert to its prior guidance on designation of nonbank financial companies as systemically important. The IAA has repeatedly urged the Council to take an activities-based approach to identifying, assessing, and addressing potential risks and threats to U.S. financial stability. We also stress the importance of strong due process provisions for any nonbank financial company under consideration for designation and supervision by the Federal Reserve Board. Specifically, we support requirements to conduct a robust cost-benefit analysis, assess the likelihood of material financial distress at the company, and consult with the company’s primary financial regulatory agency before deciding to designate any company as systemically important. Designation of individual investment advisers as systemically important should remain a measure of last resort. We also joined a letter with other trade associations in support.
