On March 25, 2026, the Financial Stability Oversight Council (the “Council”) unanimously voted to propose amendments to its interpretive guidance (the “Proposed Interpretive Guidance”) regarding the designation of nonbank financial companies as “systemically …
Sullivan & Cromwell Discusses Proposed FSOC Changes to Nonbank SIFI Designation Guidance
On March 25, 2026, the Financial Stability Oversight Council (FSOC) proposed amendments to its interpretive guidance for designating nonbank financial companies as systemically important financial institutions (SIFIs). The changes could expand the scope of regulation for fintech firms, private equity groups, and asset managers, potentially exposing them to stricter oversight and compliance burdens. Affected entities may need to reassess risk frameworks and prepare for increased scrutiny from regulators.