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FSOC annual report examines threats, opportunities facing financial markets

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Banking, Financial Stability, Inside the Beltway
Friday, January 5, 2024

The Financial Stability Oversight Council (FSOC) was unanimous in approving its 2023 annual report to Congress, reviewing the council’s take on U.S. financial market developments, potential emerging threats to financial stability and vulnerabilities in the financial system, as well as recommendations for mitigating such threats and vulnerabilities.  

The report indicated that, overall, FSOC views the U.S. financial system as remaining resilient, and the U.S. banking system as remaining sound.  The report also detailed activities undertaken by the council and summarized notable regulatory developments impacting financial markets. 

“The resilience of the U.S. financial system in the face of this year’s global economic uncertainty and the banking sector distress of the spring is a testament to the reforms implemented in the aftermath of the global financial crisis,” Secretary of the Treasury Janet Yellen said in a press release. “Events over the past year continue to underscore the importance of the council’s ongoing efforts to enhance the resilience of the financial system and monitor a wide range of vulnerabilities.” 

One of the council’s major priorities has been reviewing capital rules regulating the banking sector, intended to promote improved risk mitigation, improved resolution plans, and increased monitoring of uninsured deposit levels and depositor composition. These efforts are driven by lessons learned from past turmoil in the wake of the 2008 financial crisis and the need to reduce financial stability risks, as described by the council.

“The banking system faces a challenging environment that includes higher interest rates and concerns about the economic outlook and credit quality,” the report states. “The council recommends banking supervisors, including credit union supervisors, continue to ensure that banks maintain adequate capital and liquidity, sound interest rate risk management practices, and well-developed operational resilience plans.”

Cybersecurity poses pervasive risks within the financial system. In its report, FSOC advocates for partnerships to share actionable information, promote resilience and work together to mitigate financial disruption caused by cyber incidents.

“An incident that causes a loss of customer confidence in the confidentiality, reliability, and safety of their data, assets, and transactions at a financial institution could lead to significant withdrawals of assets, resulting in market losses,” the report states. “Additionally, a cybersecurity incident involving the theft or unauthorized disclosure of sensitive data has privacy implications for consumers and could lead to identity theft and fraud.”

Artificial intelligence (AI) represents perhaps the most significant source of technological advancement affecting the financial marketplace and the economy at large. Despite its potential benefits, FSOC also recognized the possible vulnerabilities AI could introduce to financial markets. It encouraged monitoring AI development to adapt oversight structures, deepen expertise and identify emerging risks.

“Financial institutions currently use AI for various tasks, including fraud prevention and detection, customer service, document review, and retail credit underwriting,” the report stated. “Some institutions use AI extensively, while others take a more limited approach. Even within a single institution, AI may be used to varying degrees in different areas. The use of AI, however, can introduce certain risks, including safety-and-soundness risks like cyber and model risks. Other potential risks include consumer compliance risks, which can be exacerbated by certain characteristics of many AI approaches, such as difficulty in explaining the model or understanding how it functions.”

FSOC has increased its focus on nonbank institutions’ role in financial services and associated risks as well. This includes nonbanks’ role in the mortgage marketplace, which has grown significantly in recent years.

“[T]he council’s Nonbank Mortgage Servicing Task Force, a working group including staff from member agencies and other government agencies such as the Department of Housing and Urban Development, is facilitating interagency coordination and additional market monitoring of the risks that nonbank mortgage servicers pose to U.S. financial stability,” the report notes.

The report further detailed the council’s support for initiatives geared to assess risks from mortgage servicers, private credit, hedge funds and money market funds. It also explains its advocacy for data improvements and more regulatory engagement.

Additionally, FSOC described its increased efforts to effectively evaluate and address climate-related financial risks in 2023. The council recommended enhanced data coordination, risk assessment and consistent disclosures among financial entities to enable informed decisions considering climate-related financial risks.

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