Risk Management


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
Joint-Trade Comment on CFTC Cross-Border Proposal

FSR and six other financial trade associations express their concern with a proposal by the Commodity Futures Trading Commission (CFTC) to register and regulate entities defined as “Foreign Consolidated Subsidiaries.” As the letter notes, these entities are already subject to the prudential rules of the foreign jurisdiction in which they...

Letter to FDIC on Proposed Mandatory Stay Requirements for Certain QFCs

Shortened Settlement Cycle for Securities Transactions

FSR supports efforts by the Securities and Exchange Commission to reduce the time that securities transactions are settled from three to two days. The proposed change will have a positive impact on systemic risk. FSR does note, however, that the proposed changes will also have impacts on other SEC settlement rules and asks that the SEC allow some...

Letter to FINRA on Mitigating Financial Exploitation

FSR expresses its support for a proposal by FINRA that would allow broker-dealers to withhold distributions from the account of vulnerable adults when there is reasonable evidence of financial exploitation. FSR believes covered firms should be given twelve months to conform to the new standards, and that certain clarifications should be added to...

Amendments to Federal Reserve Capital Planning and Stress Testing Rules

FSR supports the Federal Reserve’s proposal to no longer use qualitative criteria as the basis for objecting the annual capital plans of so-called “large and noncomplex” institutions. FSR members, however, do request that the Federal Reserve provide more information on the supervisory processes and documentation requirements for assessing...