FSA sets out the overall role and objectives of the FSC

However, the extent of its involvement in the identification of
SIFIs or the development of regulations with systemic – cyclical or structural – implications
(e.g. Capital buffers for SIFIs, or margin requirements for over-the-counter (OTC)
derivatives) or their implementation is not fully clear. This is also the case for crisis
management and resolution of a failing institution with potential systemic consequences,
particularly since several FSC members may be involved in those decisions within their
respective institutions. 18 In both instances, the FSC’s involvement may need to be more
clearly defined in order to avoid overlaps, gaps and possible confusion vis-à-vis the
responsibilities of its member institutions and to enhance accountability.

The authorities indicate that some of these issues are discussed in the FSC as needed (e.g. The
calibration of the macroprudential tools set forth in CRD IV/CRR), but that the FSC is not
necessarily steering the debate and that each member institution has the mandate and
authority to act if the need arises. The current division of responsibilities within the FSC is
based on each member’s respective competencies, but there could be instances in the future
whereby disagreements could arise as to whether an issue should be discussed by the FSC or
not. It may therefore be preferable – both for transparency and accountability purposes – if
there was greater clarity on the types of issues that are within the scope of the FSC for
discussion and for decision-making purposes.