Key takeaways:

• Earlier this month, federal regulators took two important steps toward finalizing the framework for designating systemically important financial institutions ("SIFIs").
• Firms that are designated as SIFIs -- which could include private funds and their managers -- will be subject to enhanced supervision and regulation under the Dodd-Frank Act, and the recently announced regulatory steps suggest that we are closer to the date when the first firms will be designated.
• Federal regulators have not indicated that private equity firms or funds are a prime target for SIFI designation, but regulators have said that, following their receipt of Form PF submissions, they will review the criteria they are using for designation determinations and may tailor those criteria for application to the asset management industry.