US counsel have warned that the country’s systemic risk regime will filter into the mid-market. Despite their stated intention, many of the rules are not expected to apply exclusively to institutions deemed systemically important (Sifis).
The Volcker rule, Collins amendment, Lincoln amendment and resolution plans are examples of tougher rules being blended across the spectrum of financial institutions.
“I think it’s inevitable that we are going to see some bleeding of the Sifi concept and principles down into the larger financial services system,” said Morrison & Foerster partner Oliver Ireland, speaking at a firm seminar on July 7.
“It’s going to be difficult for the regulators to not start applying some of those gold standards to the broader population,” he said.