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MBA Letter to Financial Stability Oversight Council (FSOC) on Proposed SIFI Designation Guidance

2023 Bank Regulatory Policy Comment Letters Commercial / Multifamily Consumer Financial Protection Bureau (CFPB) Federal Banking Regulations Government Lending Government Servicing Policy Issue Residential
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MBA represents over 2,200 member companies, including bank and non-bank lenders, 
servicers and sub-servicers in both the residential and commercial markets. MBA supports FSOC’s goal to ensure healthy and stable financial markets, however as further outlined below, MBA recommends FSOC incorporate several improvements to the proposal and the framework when considering designation of a non-bank financial firm as a SIFI.

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