If the proposed change is adopted, and a bank fails, for any reason whatsoever, commenters would surely say, "I told you so. The bank would not have failed but for the relaxation of standards."  

That said, if a risk is not "material," there is a good argument that it should not be deemed unsafe. If a risk is material, even if unlikely, that may reasonably be regarded as unsafe.  

Firms should take this as a warning to review both their expense sharing agreements and their agreements as to how they allocate revenues and expenses on business activities that involve more than one legal entity; e.g., US and non-US firms operating globally.

The vast difference in the risk assessments promulgated by FSOC under the Biden Administration and the Trump Administration illustrates (regardless of which view any individual favors) the fact that FSOC serves no useful purpose.

The "theory" behind the creation of the organization as part of Dodd-Frank was that an agency that represented each of the major U.S. financial regulators could better assess large-scale risks than could any individual agency. However, because FSOC is largely…

There is zero logic to the penalty amounts that FINRA imposes on individuals. The broker clearly violated the rules, so there is no defense to that. But it is not clear why his fines should equal those of brokers who effectively steal significant amounts of money from customers.