FRB Requests Comment on Proposal to Use Rating System to Review Financial Market Infrastructure

Steven Lofchie Commentary by Steven Lofchie

Pursuant to the authority granted by Title VIII (Payment, Clearing and Settlement Supervision) of the Dodd-Frank Act, the Board of Governors of the Federal Reserve (FRB) requested comments on its proposal to use the rating system known as ORSOM (Organization; Risk Management; Settlement; Operational Risk and Information Technology; and Market Support, Access, and Transparency) to review financial market infrastructures (FMIs).

The FRB specified that:

  • the ORSOM rating system is a supervisory tool that the Federal Reserve will use to provide a consistent internal framework for discussing FMI assessments across the Federal Reserve's FMI portfolio;

  • the ORSOM rating system will be applied to designated financial market utilities (DFMUs) for which the FRB is the Supervisory Agency pursuant to Title VIII, other DFMUs over which the Board has supervisory authority because they are members of the Federal Reserve System, and FMIs that are operated by a Federal Reserve Bank;

  • the Federal Reserve will convey the annual rating to a DFMUs management and board of directors; and

  • the rating system is designed to link supervisory assessments and messages to the regulations and guidance that form the foundation of the supervisory program, such as Regulation H (Standards for Payment Systems) and the PSR Policy (Federal Reserve Policy on Payment System Risk).

Comments on the proposal must be submitted by January 22, 2016.

Commentary

With so many letters to work with, and the legal authority to change the terms, the FRB could have come up with a more memorable acronym than ORSOM. How about this one: "At Most 10"?

A = Access, T = Transparency, M = Market Support, O = Organization, S = Settlement, T = Technology, I = Information and O = Operations. I recognize that substituting 1O for IO is playing fast and loose with the language, but certainly, it would be within the FRB's authority to do so.

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