In seeking comment on potential risks to the U.S. financial system created by asset managers, the Financial Stability Oversight Council (FSOC) again places asset managers in its crosshairs. This crusade potentially can lead to unnecessary, costly and counterproductive regulation of asset managers. Comments are due February 23, 2015.

The FSOC request for comments casts a broad net, capturing financial institutions under a number of different regulatory regimes including registered investment advisers, banks and thrifts, insurance companies, commodity trading advisors, and commodity pool operators, through their management of separately managed accounts (SMAs) and “pooled investment vehicles” including registered investment companies, private funds (including hedge funds), bank collective investment trusts, and commodity pools. The focus of the request is the degree to which new products and activities may pose potential risks to the U.S. financial system.