Regulatory Framework For SIFIs Comes Into Focus

19 June 2012
BNA's Banking Report
As we approach the two-year anniversary of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the ‘‘Dodd-Frank Act’’), the regulatory regime applicable to systemically important non-bank financial institutions (‘‘SIFIs’’) is starting to come into focus. Recent important rulemakings by the Financial Stability Oversight Council (‘‘FSOC’’) and Federal Reserve Board (‘‘FRB’’) that pertain to which firms may be designated as SIFIs have received deserved attention. Less noticed, however, has been substantive regulatory framework that is being developed to apply to SIFIs, once designated; that framework too is coming into shape. In this article, we examine both aspects of the regulatory framework, and note which aspects have been finalized, which are still in the proposed rule stage and which are still to be released.