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Minutes of the Financial Stability Oversight Council
February 28, 2022
PRESENT:
Janet L. Yellen, Secretary of the Treasury and Chairperson of the Financial Stability Oversight
Council (Council)
Jerome H. Powell, Chair, Board of Governors of the Federal Reserve System (Federal Reserve)
Martin Gruenberg, Acting Chairman, Federal Deposit Insurance Corporation (FDIC)
Gary Gensler, Chair, Securities and Exchange Commission (SEC)
Rostin Behnam, Chairman, Commodity Futures Trading Commission (CFTC)
Rohit Chopra, Director, Consumer Financial Protection Bureau (CFPB)
Sandra L. Thompson, Acting Director, Federal Housing Finance Agency (FHFA)
Michael J. Hsu, Acting Comptroller of the Currency, Office of the Comptroller of the Currency
(OCC)
Todd M. Harper, Chairman, National Credit Union Administration (NCUA)
Thomas E. Workman, Independent Member with Insurance Expertise
James Martin, Acting Director, Office of Financial Research (OFR), Department of the Treasury
(non-voting member)
Steven Seitz, Director, Federal Insurance Office (FIO), Department of the Treasury (non-voting
member)
Charles G. Cooper, Commissioner, Texas Department of Banking (non-voting member)
Eric Cioppa, Superintendent, Maine Bureau of Insurance (non-voting member)
Melanie Lubin, Securities Commissioner, Maryland Office of the Attorney General, Securities
Division (non-voting member)
GUESTS:
Department of the Treasury (Treasury)
Nellie Liang, Under Secretary for Domestic Finance
Laurie Schaffer, Principal Deputy General Counsel
Sandra Lee, Deputy Assistant Secretary for the Council
Eric Froman, Assistant General Counsel (Banking and Finance)
Didem Nisanci, Chief of Staff
Sean Hoskins, Acting Director of Policy, Office of the Financial Stability Oversight Council
Board of Governors of the Federal Reserve System
Andreas Lehnert, Director, Division of Financial Stability
Federal Deposit Insurance Corporation
Rae-Ann Miller, Associate Director, Risk Management Policy
Securities and Exchange Commission
Amanda Fischer, Senior Counselor

Commodity Futures Trading Commission
David Gillers, Chief of Staff
Consumer Financial Protection Bureau
Gregg Gelzinis, Advisor to the Director
Federal Housing Finance Agency
Naa Awaa Tagoe, Acting Deputy Director, Division of Housing Mission and Goals
Comptroller of the Currency
Blake Paulson, Senior Deputy Comptroller for Supervision Risk and Analysis
Office of the Independent Member with Insurance Expertise
Charles Klingman, Senior Policy Advisor
Federal Reserve Bank of New York
John Williams, President and Chief Executive Officer
Richard Crump, Vice President, Capital Markets Function
Office of Financial Research
Sriram Rajan, Associate Director, Research Analysis Center
Federal Insurance Office
Philip Goodman, Senior Insurance Regulatory Policy Analyst
Texas Department of Banking
Karen Lawson, Senior Vice President for Policy, Conference of State Bank Supervisors
Maine Bureau of Insurance
Ethan Sonnichsen, Managing Director of Government Relations, National Association of
Insurance Commissioners
Maryland Office of the Attorney General, Securities Division
Vincent Martinez, General Counsel, North American Securities Administrators Association
PRESENTERS:
Update on International Market Developments
• Elizabeth Rosenberg, Assistant Secretary for Terrorist Financing and Financial Crimes,
Treasury
• Lorie Logan, Executive Vice President, Markets Group, Federal Reserve Bank of New
York
• Timothy Husson, Associate Director, Division of Investment Management, SEC
• Richard Haynes, Deputy Director, Division of Clearing and Risk, CFTC
• Michael Gibson, Director, Division of Supervision and Regulation, Federal Reserve
• Rahul Prabhakar, Deputy Assistant Secretary for Cybersecurity and Critical
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•
•
•

Infrastructure Protection, Treasury
Andy Baukol, Principal Deputy Assistant Secretary for International Monetary Policy,
Treasury (available for questions)
David Saltiel, Deputy Director, Division of Trading and Markets, SEC (available for
questions)
Rahul Varma, Associate Director, Division of Market Oversight, CFTC (available for
questions)

Executive Session
The Chairperson called the executive session of the meeting of the Council to order at
approximately 5:31 P.M. The Council convened by videoconference. The Chairperson outlined
the meeting agenda, which had previously been distributed to the members. The agenda for the
executive session included an update on international market developments related to Russia’s
invasion of Ukraine.
1. Update on International Market Developments
The Chairperson turned to the meeting agenda item, an update from member agency staff on
international market developments related to Russia’s invasion of Ukraine. She stated that she
called the meeting so that Council members could share information about the latest
developments related to the Russian invasion. She noted that Treasury and other parts of the
federal government, together with U.S. allies, were forcefully responding to the invasion. She
stated that over the preceding several days, the United States had taken swift and decisive actions
to impose costs on Russia and its leadership for its attack on a democratic nation. She said that
U.S. sanctions targeted the core infrastructure of Russia’s financial system, including its central
bank and the 10 largest financial institutions in Russia. She said that U.S. government actions
were preventing President Putin from accessing most of the $600 billion of international reserves
that he intended to rely on to minimize the impact of sanctions. She stated that Russia would not
be able to access its assets that are held either in the United States or in U.S. dollars. She said
that this would likely cause the ruble to fall even further and Russian inflation to spike.
The Chairperson stated that these types of actions had never been taken against an economy the
size of Russia’s, at such a rapid pace, and with such a broad coalition, including the largest
economies of the world. She said that if the invasion continued, the United States may take
additional steps that would further isolate Russia from international finance. She stated that U.S.
financial institutions would play an important role in ensuring that sanctioned individuals and
entities are cut off from the U.S. financial system. She noted that while the actions of the United
States and its allies would be costly to Russia, the United States would need to monitor how
these efforts affect financial markets more broadly, including commodity markets. She stated
that the United States faced significant uncertainties, and that markets may be volatile as events
unfolded. She said that the United States may also face heightened cyber risks that would
require close coordination. She emphasized the importance of the Council collaborating on
member agencies’ steps and working together to monitor events occurring in regulated firms and
markets. She noted that the Council is a key forum for members to share information, identify
emerging risks, and coordinate on next steps. She said that today, the Council would hear
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several presentations, beginning with an update from Treasury staff on U.S. sanctions and other
actions, followed by updates from staff of the Federal Reserve Bank of New York, SEC, CFTC,
Federal Reserve, and Treasury.
The Chairperson then introduced Elizabeth Rosenberg, Assistant Secretary for Terrorist
Financing and Financial Crimes at Treasury. Ms. Rosenberg described the principles that guided
Treasury in establishing sanctions in response to the invasion of Ukraine. She noted that
Treasury had worked closely with partners and allies from the European Union, United
Kingdom, Canada, and elsewhere to limit Russian access to the global financial system. She
provided an overview of restrictions imposed on Russian financial institutions, including
transactions with the Russian central bank, restrictions on dealing in Russian sovereign debt, and
sanctions on individuals and companies designated as “Specially Designated Nationals”;
restrictions on certain individuals; and restrictions on trade in certain sectors. She noted that
energy transactions had been excluded from these restrictions.
The Chairperson then introduced Lorie Logan, Executive Vice President in the Markets Group at
the Federal Reserve Bank of New York. Ms. Logan discussed the impact of U.S. sanctions on
Russian financial markets, noting that the Russian central bank had announced capital controls
and closed the Moscow Stock Exchange. She noted that the sanctions had had significant effects
and reduced liquidity in Russian markets. She then discussed the potential impacts of these
actions on U.S. markets, including on commodity markets and broader financial conditions.
Finally, she discussed potential financial risks, including related to energy prices.
The Chairperson then introduced Timothy Husson, Associate Director of the Division of
Investment Management at the SEC. Mr. Husson said that the SEC was monitoring markets and
conducting outreach to market participants. He noted that U.S. markets were operating
normally, and while volumes and volatility were high in some segments, there were no reports of
systems disruptions or disruptions to key service providers. He said that the total direct exposure
to Russia of U.S.-registered and U.S. private funds was very small, and he noted that money
market funds had no direct exposure to Russia. He also discussed potential risks to energy
markets and cyber risks.
Members of the Council then had a discussion about market reactions to the sanctions.
The Chairperson then introduced Richard Haynes, Deputy Director of the Division of Clearing
and Risk at the CFTC. Mr. Haynes stated that CFTC-regulated entities had engaged in
significant risk-management preparation over the preceding weeks, for example increasing
margin requirements for certain energy contracts. He described the efforts of clearing entities
with Russian clients to wind down those positions with those clients, and noted that these
winddowns were not expected to result in market disruptions. He said that while sovereign
credit-default swaps on Russia are often cleared, no disruptions had occurred or were expected to
occur. He concluded by discussing price volatility in ruble futures, noting that they are settled in
U.S. dollars.
The Chairperson then introduced Michael Gibson, Director of the Division of Supervision and
Regulation at the Federal Reserve. Mr. Gibson discussed the Federal Reserve’s coordination
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efforts with domestic and foreign banks, in collaboration with the FDIC and OCC. He described
banks’ direct exposures to Russia, noting that they are in the process of winding down their
positions with sanctioned Russian banks. He also described the impact of sanctions on the
foreign exchange swap market and potential cyber risks.
The Chairperson then introduced Rahul Prabhakar, Deputy Assistant Secretary for Cybersecurity
and Critical Infrastructure Protection at Treasury. Mr. Prabhakar provided an overview of the
current cybersecurity status of the U.S. financial sector in relation to the Russian invasion of
Ukraine. He said that Treasury was working closely with firms and agencies to monitor for
several types of potential cybersecurity incidents, including disinformation, outages of websites
and other applications, and destructive malware both overseas and domestically. He said that
Treasury had not identified a significant or severe increase in such activity in the U.S. financial
sector or in the foreign operations of U.S. entities in connection with the current conflict. He
noted that Ukraine’s banking sector had maintained operations since the Russian invasion began
on February 24.
Mr. Prabhakar said that Treasury was collaborating with financial firms and U.S. government
agencies to discuss suspicious and malicious cyber activity in Ukraine and other countries and to
share technical information to help financial entities better defend their networks and systems.
He said that Treasury was in contact with security organizations at financial firms to understand
their potential cybersecurity and physical risks and had urged them to update and test their
response and recovery protocols. He discussed efforts by Treasury to engage with key financial
sector cybersecurity bodies to exchange updates and identify areas for follow-up. He also
discussed certain protocols that Treasury intended to follow if it receives information that an
adversary has targeted a U.S. financial firm or agency. He discussed efforts by Treasury to share
information regarding potential cybersecurity events across the domestic and international
regulatory community, including through the Financial and Banking Information Infrastructure
Committee (FBIIC). He said that as the situation in Ukraine evolves, Treasury would continue
to closely monitor the sector and share information with federal and state regulators and financial
firms.
Members of the Council then had a discussion about further collaboration among member
agencies to monitor developments in financial institutions and markets; potential macroeconomic
effects of U.S. sanctions; potential effects of actions to disconnect certain designated Russian
entities from the Society for Worldwide Interbank Financial Telecommunication (SWIFT)
network; and the potential impact of the sanctions on certain commodity markets.
The Chairperson adjourned the meeting at approximately 6:21 P.M.

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