Senate Proposal: Welcome Enhancements to SIFI Process?


In a proposal put forth by the Senate Banking Committee on May 12, 2015, there are several provisions to modify the Dodd-Frank Act.

The proposal includes an entire section dedicated to non-bank financial institutions, and calls for, among other items,

“Notices and explanations of why FSOC is considering it for SIFI designation during various stages in the designation process; opportunities to meet with FSOC or its representatives, have a hearing and submit remedial plans; an analysis of any remedial plan submitted as well as a chance to meet with FSOC representatives to discuss an analysis as well as opportunities to revise the plan; and provide a detailed explanation should FSOC decide to designate the company as a SIFI.”

Further, at a SIFI’s annual review, FSOC must vote on whether to rescind the designation and if not give the SIFI an explanation of FSOCs reasoning.

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