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CFA Institute Systemic Risk Council Writes in Support of Addressing the Growing Systemic Vulnerabilities Posed by Credit Risk Transfer Transactions

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 Writes in Support of Agencies’ Efforts to Implement the Basel III International Standards for Large Banks

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, […]

CFA Institute Systemic Risk Council Writes in Support of Proposed Rules on Long-term Debt Requirements

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 […]

CFA Institute Systemic Risk Council Adds New Members

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 […]

CFA Institute Systemic Risk Council Writes in Support of the US SEC Proposed Covered Clearing Agency Resilience and Recovery and Wind-Down Plans

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 […]

CFA Institute Systemic Risk Council Writes to Treasury Secretary Yellen on Non-Bank Financial Institutions

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) […]

CFA Institute Systemic Risk Council Writes in Support of the US SEC Proposed Rules for Open-end Funds

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 […]

CFA Institute Systemic Risk Council Writes in Support of the US SEC Proposed Rules for Money Market Funds

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% […]

CFA Institute Systemic Risk Council Urges FSOC to Address the Risks to U.S. Financial Stability Posed by Unregulated and Underregulated Stablecoins

            We write to urge the Financial Stability Oversight Council (FSOC) to address the risks to U.S. financial stability posed by unregulated and underregulated stablecoins. The President’s Working Group on Financial Markets, along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC), recently released a report recommending that Congress address these risks by passing new legislation that would impose needed regulations on stablecoin issuers and the stablecoin market. We agree with this report that a legislative response would help mitigate threats posed by unregulated stablecoins. We also believe that such legislation could help address risks posed by other underregulated monetary instruments.