In a comment letter, the SIFMA Asset Management Group
("SIFMA AMG") expressed support for a
proposal by the Financial Stability Oversight Council
("FSOC") to change existing interpretive guidance to
include adopting an "activities-based approach" to
address systemic risk issues. Under
the approach, FSOC would identify, evaluate
and address potential risks to U.S. financial stability that arose
from particular activities and would seek to adopt regulations
applicable to those activities, rather than impose requirements on
a single entity.
SIFMA AMG agreed that the proposed guidance would improve
FSOC's ability to identify and mitigate risks to U.S. financial
stability. In order to better "enhance, clarify and refine the
strong foundation" outlined in the proposed guidance, SIFMA
AMG advised FSOC to:
