Tackling section 165 of the Dodd-Frank Act

Analysis of the Dodd-Frank Act has so far focused mainly on the swap carve-out clause and requirements for central clearing. But section 165 on prudential standards also raises some difficult questions, writes Barry Schachter

Section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act contains some juicy morsels for risk managers. This part of the act focuses on prudential standard-setting, and mostly applies only to bank holding companies with more than $50 billion in consolidated assets and non-bank financials that the Financial Stability Oversight Council deems systemically important under criteria yet to be developed.

The section covers risk governance, risk measurement, risk disclosure, risk