Risk Management

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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/Joint Trades Letter to U.S. Senators on Data Security, 2-5-14

February 5, 2014

Target and Neiman Marcus have testified before the House and Senate about their breaches and, to their credit, have accepted their share of the responsibility and have pledged to work with law enforcement, the financial industry, and Congress to find ways to better protect consumers. Unfortunately, others in the retail industry have not taken this approach. They have made, and continue to make, several misleading and counterproductive statements about the breaches and the position of banks and credit unions across the country. The above bank and credit union organizations would like to set the record straight.

FSR/Joint Trades Letter to U.S. House Members on Data Security, 2-5-14

February 5, 2014

Target and Neiman Marcus have testified before the House and Senate about their breaches and, to their credit, have accepted their share of the responsibility and have pledged to work with law enforcement, the financial industry, and Congress to find ways to better protect consumers. Unfortunately, others in the retail industry have not taken this approach. They have made, and continue to make, several misleading and counterproductive statements about the breaches and the position of banks and credit unions across the country. The above bank and credit union organizations would like to set the record straight.


FSR: Insurance Patchwork Must Be Modernized for U.S. to Compete

February 5, 2014

“A competitive marketplace is the best mechanism for growing the American economy,” said Anthony Cimino, interim head of government affairs of FSR. “The existing insurance regulatory patchwork relies on a complex web of more than 50 separate state-based regulatory systems and 99 state legislative bodies, each with its own procedures, regulations, and legal definitions of insurance. It’s time to modernize our insurance system.”

It’s Time to Mend Our Insurance Patchwork

February 4, 2014

In the United States, the business of insurance is regulated at the state level, although many federal statutes and regulations also apply to insurance companies. The existing regulatory patchwork relies on a complex web of more than 50 separate state-based regulatory systems and 99 state legislative bodies, each with its own procedures, regulations, and legal definitions of insurance. This structure has deficiencies that should be addressed to further strengthen our market and meet consumers’ needs more efficiently.


“The FIO’s Report on Modernizing Insurance Regulation” – FSR Testimony, 2/4/14

February 4, 2014

My testimony will (1) detail the need for a strong, effective Federal Insurance Office; (2) identify the principles FSR believes should underpin insurance regulatory modernization; (3) address certain Report recommendations in greater detail; and (4) urge Congress and FIO and NAIC to develop an action plan to spur needed modernization of the insurance regulatory system.

FSR Sends Industry Letter to Congress on ‘Safeguarding Consumer Financial Data’

February 3, 2014

“Protecting customers and the financial system from a cyber attack is at the top of mind for financial services CEOs,” said Tim Pawlenty, CEO of FSR. “The financial services sector has taken many steps to protect customers and is among the most prepared of all sectors. But we need to stay ahead of cyber attackers and it is critical that Congress move forward on cyber threat information sharing legislation.”


Letter to Congress re: “Safeguarding Consumers’ Financial Data”, 2-3-14

February 3, 2014

In all data breaches, including the recent retailer breaches, the financial services industry’s first priority is to protect consumers from fraud caused by the breach. Banks and credit unions do this by providing consumers “zero liability” from fraudulent transactions in the event of a breach. Although financial institutions bear no responsibility for the loss of the data from a retailer’s system, they assume the liability for a majority of the resulting card-present fraud. In most instances, financial institutions have historically received very little reimbursement from the breached entities – literally pennies on the dollar.

Financial Industry Associations Submit Comments to US Regulators on Liquidity Coverage Ratio

February 1, 2014

The Clearing House Association L.L.C., the American Bankers Association (ABA), the Securities Industry & Financial Markets Association (SIFMA), the Financial Services Roundtable (FSR), the Institute of International Bankers (IIB), the Structured Finance Industry Group (SFIG), and the International Association of Credit Portfolio Managers (collectively, the “Associations”) yesterday evening filed a comment letter with the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve, and the Federal Deposit Insurance Corporation on the proposed rules regarding the liquidity coverage ratio (LCR).


Joint Trades Letter, Liquidity Coverage Ratio: Liquidity Risk Measurement, Standards, and Monitoring – 1/31/14

January 31, 2014

The Clearing House Association L.L.C., the American Bankers Association, the Securities Industry & Financial Markets Association, the Financial Services Roundtable, the Institute of International Bankers, the International Association of Credit Portfolio Managers and the Structured Finance Industry Group (collectively, the “Associations”) appreciate the opportunity to comment on the notice of proposed rulemaking by the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “Federal Reserve”) and the Federal Deposit Insurance Corporation (the “FDIC” and, collectively, the “Agencies”), entitled Liquidity Coverage Ratio: Liquidity Risk Measurement, Standards, and Monitoring (the “U.S. Proposal”).

FSR Statement on State of the Union Address

January 29, 2014

“It is encouraging the President called for action on the critical issue of housing finance reform,” said Tim Pawlenty, CEO of FSR. “Reforming Fannie and Freddie so that taxpayers are no longer on the hook is critical and the time to act is now.”