Comment from Adam Rosenberg, Individual

I support the FSOC’s proposed rule on the designation of certain financial companies to be under the supervision of the Board of Governors. The list of ten specific considerations that the Council laid out, as specified in the Dodd-Frank Act, seem to be comprehensive in terms of dealing with issues that could a financial firm to threaten the financial system as a whole. Issues of size, leverage, interconnectedness seem to be well-addressed in the Council’s rule. Also important is the consideration of liquidity risk, which this past financial crisis proved was a big factor in firm failures. One issue I might have with the rule is that the consideration of existing regulatory scrutiny might leave some firms untouched if that scrutiny is insufficient. Obviously, having the Federal Reserve watch over a firm that is already being regulated may cause confusion among the regulators and harm the firm’s ability to operate, but that’s small change compared to a potentially harmful firm being allowed to operate as it pleases. Besides this one concern, FSOC’s rule is a solid one.