This FSB resolution protocol builds on the final key attributes for effective resolution specifically to address systemic firms that hold other people’s assets. It is intended to cover a broad array of entities that do so – asset managers, prime brokers, custody banks, and others – but may in practice apply in the near term only to banks in relevant business lines since resolution implementation has barely begun for non-banks. Costs associated with this protocol – for example, those requiring significant data and operational controls for commingled accounts – could prove particularly significant, with clients perhaps reluctant to select firms well-prepared for resolution should this come at cost to them.
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