On February 4, 2015, the US Financial Stability Oversight Council (“FSOC”) adopted certain changes relating to the process of reviewing nonbank financial companies for systemically important financial institution (“SIFI”) designation to make the process more transparent and collaborative. Section 113 of the Dodd-Frank Wall Street and Consumer Protection Act (“Dodd-Frank Act”) enables the FSOC to identify a nonbank financial company for supervision by the Board of Governors of the Federal Reserve System (“Federal Reserve Board”) and be subject to enhanced prudential standards. The changes belong in three categories: (i) improved communication and engagement with companies under consideration by the Council; (ii) better transparency with the public in regards to the designations process, while still protecting sensitive, nonpublic company information; and (iii) improved engagement during the FSOC’s annual reevaluations process.

The FSOC supplemental procedures are available here:

http://www.treasury.gov/initiatives/fsoc/designations/Documents/Supplemental%20Procedures%20Relate d%20to%20Nonbank%20Financial%20Company%20Determinations%20-%20February%202015.pdf and the updated Frequently Asked Questions are available here: http://www.treasury.gov/initiatives/fsoc/designations/Pages/nonbank-faq.aspx