The SBAI supports the latest efforts by the regulators to understand and address any potential risks emanating from non-bank financial institutions (NBFI) and welcomes its findings which indicate resilience in the financial system despite prior concerns.
In our response to this Consultation, we outline our thoughts on how existing industry practices could be improved to achieve the desired outcomes, while highlighting our concerns in relation to the publication of early details related to ongoing enforcement cases.
Over the last months, we have continued to engage and meet with the US SEC on a range of proposed rules – raising specific concerns about the unintended consequences of the Safeguarding Advisory Client Assets Rule and the Predictive Analytics Rule.