FSOC Guidance

On November 3, 2023, the Financial Stability Oversight Council (“FSOC”) finalized new procedural guidance for its use of one of its most consequential authorities:  its ability to designate nonbank financial companies as “systemically important financial institutions” (“nonbank SIFIs”).  Designation as a nonbank SIFI subjects a nonbank company to Federal Reserve supervision and prudential standards. Presented by Jeffrey T. Dinwoodie and Matthew M. Kelly, both Partners at Cravath, Swaine & Moore LLP.

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