SEC Chair Speaks on Potential Revisions to FSOC’s Non-Bank Designation Guidance

By Paul S. Atkins December 15, 2025 by renholding

Today [December 11] the Financial Stability Oversight Council (FSOC) received a briefing from Treasury staff on potential revisions to the Council’s interpretative guidance regarding nonbank financial company determinations. And I was especially encouraged to see revising the non-bank designation guidance …

What the Bank of England’s System-Wide Exploratory Scenario Exercise (SWES) Tells Us

By Eric J. Pan March 18, 2025 by renholding

In late November 2024, the Bank of England published the results of its first system-wide exploratory scenario (SWES) exercise – a year-long effort to model how various financial entities, including non-bank financial intermediaries (NBFIs) and banks, would respond to a …

SEC Chair Gensler Speaks Before the Financial Stability Oversight Council

By Gary Gensler December 10, 2024 by renholding

Thank you, Secretary Yellen, for your leadership of this council these last four years. I also want to thank my fellow council members and their staffs for the collaborative efforts we’ve all put in to ensure that the risks in …

SEC Adopts New Rule on Reporting by Private Fund Advisers

By Gary Gensler February 9, 2024 by renholding

Today [February 8], the Commission voted to adopt amendments to Form PF, an important reporting tool whereby the Commission and the Financial Stability Oversight Council (FSOC) receive reporting from private fund advisers. I am pleased to support the adoption because

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Davis Polk Discusses the FSOC Annual Report

By David L. Portilla, Luigi L. De Ghenghi, Eric McLaughlin, Gabe Rosenberg and Margaret E. Tahyar January 5, 2024 by renholding

The Financial Stability Oversight Council released its 2023 Annual Report, highlighting its 2023 activities, significant financial market and regulatory developments and potential emerging threats to U.S. financial stability. The 2023 Annual Report newly identifies artificial intelligence and insurance as vulnerabilities …

Davis Polk Discusses FSOC Revision to Nonbank SIFI Designation Framework

By Luigi L. De Ghenghi, Randall D. Guynn, Eric McLaughlin, David L. Portilla and Margaret E. Tahyar November 17, 2023 by renholding

The Financial Stability Oversight Council revised its interpretive guidance and analytic framework for FSOC’s authority to designate nonbank financial companies for Federal Reserve supervision and regulation and to otherwise monitor and respond to financial stability risks. These changes reverse key …

Sullivan & Cromwell Discusses Revised FSOC Guidance on Nonbank SIFI Designations

By Dalia O. Blass, Jay Clayton, H. Rodgin Cohen, Eric M. Diamond and Marion Leydier November 14, 2023 by renholding

On November 3, 2023, the 10 voting members of the Financial Stability Oversight Council (“FSOC” or “Council”)[1] voted unanimously to finalize (1) amendments to its existing interpretive guidance (“2019 Interpretive Guidance”)[2] governing …

SEC Chair Gensler Delivers Remarks on LIBOR Before the Financial Stability Oversight Council

By Gary Gensler August 16, 2023 by renholding

Thank you, Secretary Yellen. Thank you to all of my colleagues—not only at this table but around the globe—for their hard work putting an end to the London Interbank Offered Rate (LIBOR)

LIBOR was an innovation of the 1970s to

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Davis Polk Discusses FSOC Proposals on Nonbank SIFIs

By Luigi L. De Ghenghi, Randall D. Guynn, Eric McLaughlin, David L. Portilla and Margaret E. Tahyar May 8, 2023 by renholding

The Financial Stability Oversight Council unanimously approved two proposals for public comment regarding FSOC’s authority to designate nonbank financial companies for Federal Reserve supervision and regulation, as summarized in our deck. These proposals would reverse key aspects of changes made …

SEC Commissioner Dissents from New Rule on Private Fund Data Collection

By Hester M. Peirce May 4, 2023 by renholding

Thank you, Chair Gensler. This expansion of Form PF data collection is the latest reflection of the Commission’s unquestioning faith in the Benevolent Power of More, a faith that I do not share. We have not explained sufficiently why we

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SEC Chair Speaks on New Rule for Private Fund Data Collection

By Gary Gensler May 4, 2023 by renholding

Today [May 3], the Commission considers adopting a final rule amending Form PF, an important tool that the Commission uses to oversee private fund advisers. I am pleased to support the amendments because they will improve visibility into private funds,

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The FTX Collapse: Why Did Due Diligence, Regulation, and Governance Evaporate?

By Georges Ugeux November 30, 2022 by renholding

FTX[1] is a Bahamas-based cryptocurrency exchange founded in 2019 that, at its peak in 2021, had over 1 million users, making it the world’s third largest crypto exchange by volume. Since November 11, 2022, though, FTX has been in …

Davis Polk Discusses FSOC Report on Financial Stability Risks of Digital Assets

By Randall D. Guynn, Luigi L. De Ghenghi, Joseph A. Hall, Gabriel D. Rosenberg and Margaret E. Tahyar October 31, 2022 by renholding

The report recently issued by the Financial Stability Oversight Council (FSOC) is quite different from the other reports published so far by the U.S. financial regulators in response to Executive Order 14067 on digital assets (FSOC Report).1 Helpfully, this …

SEC Chair Gensler on Proposed Joint Amendments to Form PF

By Gary Gensler August 11, 2022 by renholding

Today [August 10], the Commission is considering whether to propose joint amendments with the Commodity Futures Trading Commission (CFTC) to Form PF, an important reporting tool that the Commission and the Financial Stability Oversight Council (FSOC) use, respectively, to protect

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SEC Chair Gensler Speaks to FSOC on Money Market Funds, Open-End Bond Funds, and Hedge Funds

By Gary Gensler February 8, 2022 by renholding

Thank you, Secretary Yellen, for focusing the Council’s attention on financial resiliency with regard to three key parts of our capital markets — particularly money market funds, open-end bond funds, and hedge funds.

The fund industry gives retail and institutional

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Davis Polk Discusses Developments in Regulation Related to Private Equity

By Gregory S. Rowland, Leor Landa, Michael S. Hong, Lee Hochbaum and Sarah E. Kim February 7, 2022 by renholding

Rules and regulations

SEC proposes amendments to bolster private fund reporting

On January 26, 2022, the Securities and Exchange Commission (SEC) voted to propose certain amendments to Form PF designed to facilitate the SEC’s oversight of private fund advisers and …

Climate-Risk Disclosures and “Dirty Energy” Transfers: “Progress” Through Evasion

By John C. Coffee, Jr. January 25, 2022 by renholding

At first glance, recent progress towards transparency in corporate climate-risk disclosures seems exceptional. Over 2,000 companies now publish annual reports showing their carbon emissions data (although most self-interestedly omit Scope 3 data). Many (including most recently ExxonMobil) have made a …

Fragile Financial Regulation

By Pradeep Yadav and Yesha Yadav September 14, 2021 by renholding

As COVID-19 rocked financial markets in March 2020, the Treasury market failed to perform its role of maintaining financial stability. Unable to respond to the surge of investors liquidating their Treasury holdings to raise cash, the secondary market ground to …

Reforming the Macroprudential Regulatory Architecture in the United States

By Kathryn Judge and Anil Kashyap July 26, 2021 by renholding

When the COVID-19 pandemic shuttered major economies in March 2020, it also wreaked havoc on financial markets. In the first few weeks of March, investment-grade corporate bonds lost roughly a fifth of their value, on par with the declines in …

Resurrecting the Office of Financial Research

By Hilary J. Allen November 30, 2020 by renholding

The Office of Financial Research (“OFR”) was created by the Dodd-Frank Act to help address the gaps in data availability and analysis that had hampered governmental authorities in their response to the financial crisis of 2008. It was hoped that …

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