SIFMA AMG Statement on FDIC Consideration of Changes to Bank “Control” Rules

Washington, D.C., July 30, 2024 - SIFMA's Asset Management Group (SIFMA AMG) today issued the following statement from Lindsey Keljo, managing director and head of the AMG, related to the consideration of changes from the FDIC on asset managers regarding "control":

"We are disappointed that the FDIC has issued a notice of proposed rulemaking and request for comment amending regulations implementing the Change in Bank Control Act. We believe the FDIC's current approach to assessing 'control' under the Change in Bank Control Act has worked well and is not in need of reevaluation. The changes under consideration could have serious unintended consequences, including a detrimental impact on banks' access to capital. The current approach among banking regulators has worked well and has avoided unnecessary and costly regulation that is ultimately borne by markets and investors. We also want to highlight the importance of considering Acting Comptroller of the Currency Hsu's concerns regarding ensuring any regulatory process includes all relevant regulatory agencies, and we appreciate the FDIC's commitment to developing an interagency approach to change in control notices.

"Millions of Americans save for retirement and other financial goals with the help of funds managed by asset managers. Investors benefit from economies of scale and are paying lower fees than ever before, largely due to the lower costs of index investing. Such funds provide investors with exposure to many sectors of the economy including banking and as such are an important source of capital for the sector. Any reevaluation of asset managers' investments in FDIC-supervised institutions must be thoughtful and designed to avoid limiting banks' access to capital or investors' ability to save for their financial goals. To do otherwise risks unduly disincentivizing investment in banks and increasing the cost of investment for retail investors in the United States.

"We stand ready to work with the FDIC and its Directors and will provide feedback through the comment period on how to address concerns without negatively impacting our markets."

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SIFMA's Asset Management Group (SIFMA AMG) brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG's members represent U.S. and global asset management firms - both independent and broker-dealer affiliated - whose combined assets under management exceed $62 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.

SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry's nearly 1 million employees, we advocate for legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.