In this proposal, the Financial Stability Board (FSB) expands its “key attributes” for orderly resolution initially designed for banks to non-bank financial institutions that are either systemic or operationally critical. Covered entities include financial market infrastructure (FMI) firms that are dubbed financial market utilities in the U.S., insurance companies, and firms holding assets under management. Here, we build on FedFin’s prior analysis of the standards as they would apply to insurers, and FMUs and their participants to assess new resolution protocols proposed for at least some of the firms that hold client assets in the course of providing other financial services. Although the approach here is less prescriptive than that of the other consultations, it would still dramatically alter the business model of covered firms, as well as add new internal-control and information-technology costs.

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