FSOC’s Updated Approach for Responding to Financial Stability Risks: New Guidance on Nonbank “SIFI” Designations

On November 3, 2023, the Financial Stability Oversight Council (“FSOC”) finalized new procedural guidance for its use of one of its most consequential statutory authorities:  its ability to designate nonbank financial companies as “systemically important financial institutions” (“nonbank SIFIs”).  Designation as a nonbank SIFI subjects a nonbank company to Federal Reserve supervision and prudential standards. 

The new guidance replaces guidance that FSOC issued in 2019 and makes it significantly easier for FSOC to designate companies as nonbank SIFIs. 

Jeff Dinwoodie and Craig Radcliffe, both of whom previously served at the U.S. Treasury Department, will provide an update on FSOC, including insights and reflections on the new guidance and what it may mean going forward.


Jeffrey T. Dinwoodie, Partner, Cravath, Swaine & Moore LLP.

Craig M. Radcliffe, Principal, Public Policy, Apollo Global Management, Inc.


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