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
FTC Letter on Safeguarding Consumer Information

FSR/BITS supports the continuation of the FTC’s rules on safeguarding information. FSR also believes that the FTC should correlate its rules with the NIST Cybersecurity Framework, and that further expansion of the rule over financial activities that are currently not covered by the FTC is unwarranted, considering the information protection...

Comment on Proposed FIO Information Collection

In response to an announcement that the Federal Insurance Office (FIO) will collect information for a study on auto insurance pricing, FSR filed a comment letter reiterating its concerns that elements of FIO’s study design are flawed, and that certain issues surrounding FIO’s data security standards should be better clarified.

Proposed Federal Reserve Capital Framework for Insurance Companies

FSR supports the Federal Reserve’s proposal to use state level standards as the basis for a consolidated capital requirement for insurance companies that fall under their jurisdiction. This proposed standard, known as the building-block approach (BBA) would leverage standards that are already in place and could be easily modified to protect...

Joint Trade Comments on the Federal Reserve’s proposed rule to establish a Net Stable Funding Ratio (“NSFR”)

FSR letter to the House HR 3340