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

FSR Comment on Federal Reserve FR Y-14 Information Collection

November 16, 2015

FSR urges the Federal Reserve to allow FR Y-14 respondents to have six months from the finalization of schedule changes before they are required to begin to report new data. FSR also presents survey data to the Federal Reserve showing that the actual hours necessary to prepare FR Y-14 submissions is greater than current Federal Reserve estimates. The letter also urges the Federal Reserve to improve its process for answering questions in response to industry questions and to reduce the frequency of changes to the FR Y-14 form. Finally, the letter opposes the Federal Reserve’s proposal to add an attestation requirement on FR Y-14 submissions and expresses support for the Federal Reserve’s plan to share FR Y-14 data with the Office of Financial Research.

Basel Proposal on Interest Rate Risk

September 15, 2015

FSR and other trades caution the Basel Committee on Banking against forcing banks to adopt risk management models that lack sufficient flexibility.

Letter to Federal Insurance Office on Proposed Definition of Auto Insurance Affordability

September 1, 2015

FSR requests that the Federal Insurance Office (FIO) withdraw its proposal to calculate a new auto affordability index. The proposal fails to recognize key factors the drive insurance pricing trends. It also would impose onerous and unreasonable reporting requirements on insurance providers. In place of the index, FSR urges FIO to urge currently available sources of data in order to monitor the affordability of auto insurance.