Dalia O. Blass, Eric M. Diamond, Marion C. Leydier, Charles C. Gray and Daniel M. Wolf

Sullivan & Cromwell Discusses Proposed FSOC Changes to Nonbank SIFI Designation Guidance

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On March 25, 2026, the Financial Stability Oversight Council (the “Council”) unanimously voted to propose amendments to its interpretive guidance (the “Proposed Interpretive Guidance”) regarding the designation of nonbank financial companies as “systemically important financial institutions” (“SIFIs”) for supervision by …