In a year when major bank failures were caused by basic risk management deficiencies, the report might have been of more value if it focused on the financial risk from mismatches in the funding of assets and liabilities, which ultimately cost billions of dollars and essentially forced the FDIC to guarantee the deposits of every bank in the United States, rather than on all the effort apparently undertaken to work on climate-related financial risk.  

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Another heads-up. The Fact Sheet contains a brief paragraph on the application of AML regulations to investment advisers, which includes the following statement:

"Treasury is re-examining the 2015 [Notice of Proposed Rulemaking] regarding this sector, and aims to issue in the first quarter of 2024 an updated NPRM that would propose applying AML/CFT requirements pursuant to the Bank Secrecy Act, including suspicious activity reporting obligations, to certain…

What does it mean to say that one is "technology neutral" as to AI? The benefits and risks of AI are specific to that technology. The reason that AI is a revolutionary technology is that it is materially different from other technologies. It is not so simple a matter as saying that a financial institution can solve a given problem faster or better by using AI than with a pen and paper, or with a rigid credit score. The regulators are having a hard time formulating policies that deal with…

The Office of Investor Advocate's discussion of RILAs is worth taking note of for two reasons. Most immediately, firms selling this product would be well-advised to review their marketing materials and their suitability reviews, particularly to the extent that the product is sold to older investors.  

More generally, this is not the first time that the regulators have questioned whether it is sufficient for the securities regulatory regime to treat "disclosure" as sufficient. In…