The Asset Management Group of SIFMA (“SIFMA AMG”) submitted comments to the Financial Stability Board (“FSB”) on the recently released FSB-IOSCO joint consultative document, Assessment Methodologies for Identifying Non-Bank Non-Insurer Global Systemically Important Financial Institutions (NBNI G-SIFIs) (January 8, 2014). The bottom line of the letter is that investment funds are not banks, and that the tremendous number of different investment funds makes it highly unlikely that any investment fund would be of systemic significance.
Beyond that fundamental conclusion, SIFMA AMG suggested that rather than trying to identify individual entities that represent concentrated risk to such a degree that they warrant different regulation than their competitors, it would be more productive to assess and regulate activities in which investment funds and other capital markets participants engage. SIFMA AMG stated, however, that it generally agrees that a consistent regulatory approach will lead to regulation that is consistent with the objective of the “SIFI Framework.”
See: SIFMA Comment Letter.