|
|
AMIC is concerned that the a priori exclusion of public financial institutions, sovereign wealth funds and pension funds could lead to an insufficient consideration of where decisions are made with regard to asset allocation. AMIC believes that the exposures/counterparty channel properly and comprehensively captures any potential systemic risks posed by the financial distress or disorderly liquidation of an investment fund at global level.
Furthermore, AMIC feel that the consultation’s assumption of three distinct transmission channels for systemic risk does not apply to investment funds. AMIC cannot imagine a scenario under which the ‘critical function or services/substitutability channel’ would ever be triggered by the distress or wind-down of an investment fund and potentially impair the financial system’s stability. With respect to the asset liquidation/market channel AMIC finds it hard to see how the liquidation of an investment fund’s assets could pose a risk to financial stability unless there is an underlying problem with the affected assets or asset class themselves in which case the issue at hand would not be the management or regulation of the respective fund(s).
AMIC also continues to question the need and relevance of cross-jurisdictional activities as a factor determining the systemic risk of NBNI G-SIFIs. Cross-jurisdictional activities should be considered a mitigating factor for systemic risk purposes. Also, cross-jurisdictional activities are too commonplace in the industry to be a useful differentiator and even purely domestic operators can become systemically important if other criteria are met.
Last but not least, FSB/IOSCO’s second consultation has not answered a significant omission from the first consultation: details about the consequences of being designated an NBNI G-SIFI. This is cause for concern among market participants due to the significant legal uncertainty for the future.