The CFA Institute Systemic Risk Council (Council) latest comment letter was submitted August 25 to U.S. bank regulators voicing strong concerns over proposed changes that would weaken key capital adequacy protections put in place during the Great Financial Crisis era (GFC), specifically, the enhanced Supplementary Leverage Ratio (eSLR), Total Loss-Absorbing Capacity (TLAC), and long-term debt […]
The CFA Institute Systemic Risk Council (the SRC) today released a letter to congressional leaders urging strong, effective regulatory oversight of the stablecoin market and commending bipartisan efforts to build consensus around a credible regulatory process for stablecoin products. Currently , there are two proposals in the Congress: the Stablecoin Transparency and Accountability for a […]
CFA Institute Systemic Risk Council (the Council) recently provided detailed comments to the Honorable Jerome Powell, Chair of the Board of Governors of the Federal Reserve System, on the growing systemic vulnerabilities to the global financial system posed by credit derivatives known as credit risk transfer transactions (CRTs). While the rapidly expanding use of these instruments […]
CFA Institute Systemic Risk Council (the Council) recently provided detailed comments on the Basel III proposals from the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation. The Council provides analysis of the so-called endgame to ensure proper framing of capital adequacy, […]
On December 10, 2023, the Systemic Risk Council (the Council) offered its response to proposed rules of the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation that would require certain large depository institution holding companies, U.S. intermediate holding companies of foreign […]
Washington, D.C. – October 4, 2023 CFA Institute Systemic Risk Council (SRC) today announced that it has added three new members to the Council. They are Dr. Elke König of Germany, René Karsenti of France and Christina Romer from the United States. Erkki Liikanen, Co-Chair of the Council said, “We are thrilled to add these three […]
On August 30, 2023, the Systemic Risk Council (the Council) offered its response to the U.S. Securities and Exchange Commission’s proposed Covered Clearing Agency (CCA) Resilience and Recovery and Wind-Down Plans’ proposal to improve CCAs’ ability to manage stressed markets through monitoring and margining practices. The Council strongly supports the Proposals as far as they […]
The Financial Stability Oversight Council (FSOC) recently voted to issue 12 CFR Part 1310 (Authority to Require Supervision and Regulation of Certain Nonbank Financial Companies) and the Analytic Framework for Financial Stability Risk Identification, Assessment, and Response (Proposed Analytics Framework or PAF) for public comment. The Systemic Risk Council believes that non-bank financial institutions (NBFIs) […]
On December 16, 2022, the Securities and Exchange Commission proposed amendments to its current rules for open-end management investment companies (“open-end funds”) regarding liquidity risk management programs and swing pricing, seeking comments by February 14, 2023. The Systemic Risk Council applauds the Proposed Rule as part of the Commission’s continuing efforts to reduce the potential […]
Letter to the US SEC April 15, 2022 Re: Release No. IC–34441; File No. S7–22–21 Dear Members of the Commission: We write in support of the proposed amendments to the Commission’s rules governing money market mutual funds. We believe that the Commission’s plan to increase the daily and weekly minimum liquid asset requirements to 25% […]