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

FTC Letter on Safeguarding Consumer Information

January 3, 2017

FSR/BITS supports the continuation of the FTC’s rules on safeguarding information. FSR also believes that the FTC should correlate its rules with the NIST Cybersecurity Framework, and that further expansion of the rule over financial activities that are currently not covered by the FTC is unwarranted, considering the information protection requirements that are already imposed by regulators that exist as part of the Federal Financial Institutions Examinations Council (FFIEC).

Comment on Proposed FIO Information Collection

September 23, 2016

In response to an announcement that the Federal Insurance Office (FIO) will collect information for a study on auto insurance pricing, FSR filed a comment letter reiterating its concerns that elements of FIO’s study design are flawed, and that certain issues surrounding FIO’s data security standards should be better clarified.

Proposed Federal Reserve Capital Framework for Insurance Companies

September 16, 2016

FSR supports the Federal Reserve’s proposal to use state level standards as the basis for a consolidated capital requirement for insurance companies that fall under their jurisdiction. This proposed standard, known as the building-block approach (BBA) would leverage standards that are already in place and could be easily modified to protect against regulatory arbitrage. FSR does not believe, however, that the Fed should create an entirely new capital formula (what it calls the consolidated approach or “CA”) for insurance companies that have been designated as “systemically important” by the Financial Stability Oversight Council.

Incentive-Based Compensation Requirements: Deadline Extension Request

June 8, 2016

FSR in cooperation with four other industry associations ask for at least a 150-day comment period to respond to a recent joint-agency proposal that places more regulations and specific limits on bonus payments to financial services employees. The associations note that allowing the public to have sufficient time to analyze the rule will ensure that regulators receive the information necessary to ensure that a final rule is properly calibrated and avoids unintended consequences.

Request for the Release of FR Y-14 Technical Instructions

February 24, 2016

In reaction to an earlier request from the industry, the Federal Reserve delayed the effective date of certain changes to its FR Y-14 information reporting forms until June 30, 2016. Unfortunately, the Federal Reserve has not yet released the technical instructions that are associated with these changes, which prevents banking institutions from adapting their systems to meet the new requirements. In view of this delay, and the Federal Reserve’s earlier recognition that the quality of data banks provide is improved by having sufficient time to update their internal monitoring systems, FSR requests that the Federal Reserve immediately release the required instructions or delay the effective date of FR Y-14 changes until September 30.