[20171201]LSB10040_更改为“太大而不能失败”？：财政部建议修订针对非银行的多德-弗兰克SIFI指定流程（第二部分）.pdf

CRS INSIGHT Prepared for Members and Committees of Congress Legal SidebarLegal Sidebari i Changes to “Too Big To Fail”?: Treasury Recommends Revisions to Dodd-Frank SIFI Designation Process for Non-Banks (Part II) December 1, 2017 As discussed in Part I of this two-part Sidebar, on November 17, the Treasury Department issued a report recommending a number of changes to the Financial Stability Oversight Councils (FSOCs) process for designating non-bank financial companies as “systemically important financial institutions” (SIFIs) (colloquially known as institutions that are “Too Big to Fail”) under the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). While Part I provides a general background on the SIFI designation process, this Sidebar discusses the legal debate over the designation process, the Treasury Departments recommended changes for the process, and how those changes may affect the Senates consideration of the Financial CHOICE Act of 2017, which would repeal FSOCs authority to designate non-banks as SIFIs altogether. The Debate over the SIFI Designation Process The SIFI designation process has been the subject of much legal debate. As discussed in Par