Earlier this month, Prudential Financial, Inc. and American International Group, Inc. confirmed that they received notice of a proposed determination by the Financial Stability Oversight Council (“FSOC”) that they should be subject to stricter prudential regulatory standards and supervision by the Board of Governors of the Federal Reserve System as systemically important financial institutions (“SIFIs”), pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act. Prudential indicated that it is evaluating whether to request a nonpublic evidentiary hearing before FSOC to contest the proposed determination, as permitted under the Act.

While FSOC has not officially disclosed the names of any companies, press reports have indicated that GE Capital is also proposed for regulation as a SIFI.

We will continue to monitor this topic and will report on the designations once they are released.