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I. Introduction
The Dodd-Frank Wall Street Reform and Consumer Protection Act is the keystone US financial system reform policy response to the financial crisis of 2007-2009[1] . Less in the limelight, but conceptually akin to much of the financial system reform agenda codified in the Dodd-Frank Act (DFA), is the policy response of the Group of Twenty (G20) nations[2] . Indeed, G20 policy deliberations on financial system reform, to which US authorities made substantial contributions, proceeded largely in tandem with the domestic debate culminating in the enactment of the DFA in July 2010. Furthermore, although the G20 policy measures to which Member nations committed at the Leaders' Summit in Seoul, Korea in November 2010 do not, as does the DFA, have the force of law, they represent an important element of the "international side" of US financial system reform policy[3] . That raises the question of whether the G20 and DFA financial reform agendas are "in sync."
The purpose of this study is to answer that question, at least for one portion of the policy agenda. The paper focuses specifically on policies to address risks to the financial system posed by systemically important financial institutions (SIFIs)[4] . The study compares the substance and timetable of specific DFA and G20 SIFI-oriented policy initiatives and ascertains the extent to which those policies are consistent with each other. The analysis concludes overall that the G20 and DFA SIFI agendas are substantively consistent and complementary. However, that conclusion is qualified in two ways. First, the two agendas differ in their relative emphasis on the coverage of both banks and nonbanks. The G20/Financial Stability Board (FSB) focus, at least over the near-term, is bank-centric compared with the DFA, which consistently addresses both bank and nonbank financial firms. Second, implementation of DFA provisions is subject to long-established US law mandating that there be sufficient opportunity for public input into the rulemaking process, whereas the G20/FSB process has been less systematic and transparent on public consultation and feedback. The lesser emphasis on transparency and public input characterizing the G20/FSB policy development process may be attributable in part to the somewhat more rapid pace of the G20/FSB agenda relative to corresponding DFA timelines.
The study is organized as follows. The background discussion in...