Regulatory Outreach for Student Education (ROSE)
Regulatory Outreach for Student Education
Engaging Students in the Debate Over Financial Services Reform
Today’s debate over regulatory reform is a watershed activity in the careers of financial industry professionals. Years ago, similar debates over mandated pre-funding of pension liabilities (ERISA) and the reunification of investment banking with commercial banking (Glass Steagall’s repeal) changed the direction of financial market evolution. Opinions may differ on the merits of those changes, but no one disputes their significance.
Without question, college students and young professionals should be well-versed in the issues involved in today’s debate. The Regulatory Outreach for Student Education (ROSE) program is the Center’s way to give top students, tomorrow’s business and finance leaders, opportunities to experience the financial regulatory process up-close. The ROSE program is designed to put students in touch with the regulators, policy-makers, and industry leaders who are currently shaping the financial regulatory landscape. We then challenge them to research and articulate their own positions on the most intriguing and interesting issues.
ROSE Program Resources and References
2016 ROSE References and Information
2015 ROSE References and Information
Regulatory Outreach for Student Education (ROSE) Blog Articles
Fordham Students Submit Comment Letters to Basel Committee
On May 16, 2016, Fordham students participating in the Center’s Regulatory Outreach for Student Education (ROSE) Program submitted their winning comment letter on the Basel Committee’s December 17, 2015 consultation, “Identification and Measurement of Step-in Risk.”
Five teams of Fordham economics, finance, accounting, and law students participating in the ROSE Program researched and drafted comment letters, which were then submitted for judging by a panel of industry experts. The letters were then submitted to the Basel Committee on Fordham letterhead.
The ROSE Program brings together students from across the university to study our financial system, how it affects society, and, specifically, current issues in financial regulation. This year’s groups included both graduate and undergraduate suduents bringing a diverse range of perspectives and skills to the task. The consultative document, with its breadth and depth, offered an excellent opportunity for them to comment.
CSMFE Submits Comments on FSB Data Collection Proposals
On February 12, 2015, the Center for the Study of Financial Market Evolution (“CSFME” or the “Center”) filed its response to the Financial Stability Board’s (FSB) consultation, Standards and Processes for Global Securities Financing Data Collection and Aggregation (“Consultation Paper”). The Consultation Paper proposes a system of data collection intended to help market supervisors infer changes in systemic risk that are said to be created by securities lenders, repo traders and margin lenders. Previously, as part of their larger workstream on shadow banking, the FSB recommended that national/regional authorities collect appropriate data on securities financing markets to help the FSB better assess ongoing financial stability. The Consultation Paper is a proposal regarding what kinds of data on repo, securities lending, and margin lending should be collected, how they should be collected, and in what format.
FSB Finalizes Standards and Processes for Global Securities Financing Data Collection and Aggregation
On November 18, 2015, the Financial Stability Board (FSB) published its final Standards and Processes for Global Securities Financing Data Collection and Aggregation. The final standards are based on the FSB’s previous November 2014 consultation paper and define the data elements for securities lending, repo, and margin lending that national and regional authorities will be asked to report in aggregate to the FSB.
The standards build on the November 2014 consultation paper, including public comments, as well the policy recommendations from the FSB’s August 2013 report Policy Framework for Addressing Shadow Banking Risks in Securities Lending and Repos, in particular its recommendations to improve transparency of securities financing markets. T
Open Consultation Papers and Rule Proposals: Winter 2014/15
The global regulatory calendar for the first quarter of 2015 includes comment deadlines for a number of consultation papers and rule proposals. We have compiled a list of the closing dates of many, if not all, of the major comment periods.
2015 ROSE Students File Comment Letters with the FSB
The focus of the Winter 2015 ROSE Program was global securities financing data collection and aggregation. This year, Five teams of Fordham University graduate and undergraduate students researched and drafted comment responses to the Financial Stability Board’s (“FSB”) November 2014 consultative document, Standards and Processes for Global Securities Financing Data Collection and Aggregation. The judges reviewed each excellent submission and selected one letter to be published on Fordham letterhead and submitted to the FSB. (Each of the teams submitted their comment letter to the FSB; however, only one received Fordham Unversity’s imprimatur.
FSB Moves for More Transparency in Repo and Securities Lending Markets
This latest consultation document is part of a larger effort by the FSB to increase transparency in “shadow banking” activities like securities lending and repo to detect financial stability risks, develop policy responses, and assess global trends in financial stability. Echoing the sentiments of Mr. Carney, Daniel Tarullo, Chairman of the FSB Standing Committee on Supervisory and Regulatory Cooperation, stated that “timely, comprehensive and consistent data collection is essential for authorities in identifying the build-up of leverage and other financial stability risks in global securities financing markets. The implementation of the proposed standards and processes will allow authorities to establish a monitoring framework to support their efforts to effectively address financial stability risks stemming from securities financing.”
List of Open Consultations and Rule Proposals
With the November 15 and 16 G20 Summit in Brisbane fast approaching, policy makers and regulators in the US and the UK have been hard at work. Not to be outdone, IOSCO, ESMA, and BIS have also been busy. Eager to demonstrate progress on financial re-regulation and reform, there has been a flurry of consultation papers and rule proposals at all levels over the past quarter. The following is a list, current as of October 9, 2014, of some of the more noteworthy proposals and consultation papers whose comment periods are currently open. It should be noted that a number of these consultations close imminently.
CSFME Encourages Fordham Students to Let Their Voices Be Heard
In a web based meeting today, CSFME’s Executive Director Ed Blount and Senior Policy Analyst David Schwartz met with a group of Fordham University’s graduate and undergraduate business students to invite them to participate in the real world of regulatory policy. The focus of this meeting was the Financial Stability Board’s recent proposal regarding the “Assessment Methodologies for Identifying Non-Bank Non-Insurer Global SIFIs.” After a brief discussion of some of the goals of the FSB’s proposal and some the most provocative issues raised by the consultative document, Messrs. Blount and Schwartz challenged the students to research and formulate their own positions on the consultative document with an eye on submitting formal comment letters to the FSB.
CSFME Outreach Programs
DLT Securities Finance Initiative
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