The Asset Management Group of SIFMA (SIFMA AMG) provides comments to the Financial Stability Board (FSB) on the FSB’s and the International Organization of Securities Commissions’ (IOSCO) joint Consultative Document, Assessment Methodologies for Identifying Non-Bank Non-Insurer Global Systemically Important Financial Institutions (G-SIFIs).

SIFMA AMG acknowledges it is difficult, if not impossible to design a methodology for identifying companies that may warrant different regulation without knowing what the regulation will be. SIFMA AMG generally agrees that a consistent regulatory approach will lead to regulation that is consistent with the objective of the “SIFI Framework.”

SIFMA AMG believes it would be more productive to assess and regulate activities in which investment funds and other capital markets participants engage than it would be to try to identify individual entities that represent concentrated risk to such a degree that they warrant different regulation than their competitors.

SIFMA AMG requests that the FSB and IOSCO shift the focus of the investment fund assessment methodology from investment funds to their activities.

Related, see: SIFMA AMG Submits Comments to the FSB and SEC in Response to OFR Study and in Regards to Separate Accounts  (April 4, 2014)