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
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
"It’s going to be difficult for the regulators to
not start applying some of those gold standards to the broader
population," he said. ...