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The ICMA Asset Management and Investors Council (AMIC) welcomes the opportunity to respond to this consultation by the Financial Stability Board (FSB) on proposed policy recommendations to address structural vulnerabilities from asset management activities.
AMIC strongly welcomes the approach by the FSB to focus on the activities of asset managers rather than designating individual companies as systemically important. However, AMIC cautions against returning to the designation debate.
In their response to the second consultation on designating non-bank non-insurance global systemically important financial institutions (NBNI G-SIFIs) in 2015, they called for a consideration of the broader market ecosystem and in particular a greater focus on the activities that cause risk rather than the entities that cause risk.
AMIC also notes that any effort to harmonise leverage calculation should not impact the existing methods to calculate fund leverage established through European legislation.