Mr. ZARING.

• I don’t think that the institutions that the Council has considered and carefully considered would want all of the information that they provide the Council in discussing and indeed sometimes contesting their designations to be released to the public and to their competitors and to the financial marketplace, more generally.
• Some of the things that FSOC does that some of the witnesses here seem to believe are sort of secret are the kinds of secrets that businesses want the government to keep.
• And I think it is responsible for FSOC to keep those secrets for the businesses they are reviewing.

Mr. GREEN.

• Speaking of keeping secrets, there is a desire on behalf
  of some to have Congresspersons in the room when these deliberations are taking place.
• Is that going to be beneficial to secrecy, and how do you think that will impact the process?

Mr. ZARING.

• No, I don’t think agencies or businesses benefit from having their deliberations, internal deliberations before a decision is rendered, being open for nitpicking or after the fact.
• It is, at worst, Monday-morning quarterbacking.
• What you should do is evaluate the decision and expect that decision to be carefully articulated.

2017 0328 - GOV - THE ARBITRARY AND INCONSISTENT NON-BANK SIFI DESIGNATION PROCESS

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