Risk Management


FSR advocates for the development of robust risk management practices that protect the financial and reputational strength of financial institutions, their customers, and the financial system. Risk management priorities cover insurance industry, systemic risk, prudential risk, and enterprise risk issues.

Policy discussions in this area are continually informed though input for executives that serve on the FSR Risk Management Policy Committee as well as the FSR Chief Risk Officers Council.

Current Risk Management Priorities:

  • Cybersecurity
  • Federal Government Involvement in Insurance Regulation
  • Reauthorization of the National Flood Insurance Program
  • Capital Planning & Stress Testing Requirements
  • Resolution and Recovery Plan Requirements
  • The Designation Process of the Financial Stability Oversight Council
  • Patents and Intellectual Property
  • Capital Standards for Financial Entities (Bank & Non-Bank)
  • Bankruptcy Reform and “Too Big to Fail” Issues
  • Swaps & Derivatives

“Ownership Interests” in Connection with Certain CLO Debt Securities, 3rd Letter

January 12, 2014

We submit this letter on behalf of the undersigned organizations as a follow-up to the meetings and to our letters of December 24, 2013 and December 31, 2013 (the “December Letters”), to clarify certain aspects of those letters and the discussions in the January 9 Meetings, and to propose language that would confirm, in a FAQ or other appropriate interpretive guidance, that the term “ownership interest” as defined in §__.10(d)(6) of the final rule implementing the Volcker Rule does not include debt securities of collateralized loan obligation (“CLO”) issuers that are covered funds, as described below, solely because they have the creditor-protective rights described below, whether or not an event of default or acceleration event exists under the CLO indenture.

Supplemental Letter on “Ownership Interests” in Connection with Certain CLO Debt Securities, 12-31-13

December 31, 2013

We respectfully request that the Agencies consider our request for confirmation that the CLO debt securities described in the December 24 Letter are not “ownership interests” at the same time, and in the same administrative proceeding, that it considers relief for debt security holders of collateralized debt obligations (“CDOs”) backed by trust preferred securities (“TruPS”).

FSR CLO Clarification Letter Release, 12/29/13

December 29, 2013

Financial Services Roundtable (FSR), along with four other financial trade associations sent a letter to federal regulators earlier this week seeking confirmation that certain debt securities of collateralized loan obligation (CLO) issuers that are “covered funds” are not “ownership interests” as defined by the final Volcker Rule.

Bankers Say Agencies’ Answer on CDOs Under Volcker Falls Short

December 19, 2013

Fine’s group, the ABA and the Financial Services Roundtable sent letters to regulators this week seeking guidance before the end of the year on the rule adopted by the Federal Reserve, Federal Deposit Insurance Corp. and three other agencies on Dec. 10.

Regulators fail to fix unintended consequences of Volcker

December 19, 2013

Guidance issued today by federal bank regulators leaves open questions that will result in negative unintended consequences from the finalized Volcker Rule. The provision clarified today regarding trust preferred securities (TruPS) will likely result in significant losses for financial institutions.

Fed Said to Delay Bank Leverage Rule Until Basel Plan Ready

December 18, 2013

The financial industry has criticized the U.S. standards as too high. They “would effectively require much more capital to be held for banks’ least risky assets,” according to an Oct. 21 comment letter to regulators from the American Bankers Association, Financial Services Roundtable and the Securities Industry and Financial Markets Association. Going ahead of Basel is “putting the cart before the horse,” according to the letter. “Any final calibration should be set at an international level to ensure global consistency.”