Geithner, the council's chairman, suggested in September that such a list could encompass New York-based American International Group Inc., the bailed-out insurer, and GE Capital, a unit of Fairfield, Conn.-based General Electric Co. that benefited from a government backstop for financial-company debt. The Treasury chief has indicated he'd like regulators to have some discretion in assessing risk.
"There's no objective standard for what's systemic," Geithner told the Financial Crisis Inquiry Commission in 2009 testimony released in February. "It's only a judgment you can make at the time."
Asset Managers
The study said asset-management firms could be required to fill out a new form on so-called gross notional exposure "to give an indication of whether the firm takes large derivatives positions." Notional refers to the face value of a contract rather than a firm's cost of purchasing an agreement.
Specialty lenders that, for example, offer financing for education needs or big-ticket purchases could be subject to a new industry survey. Data such as a firm's market share of assets can capture "how difficult it would be for other firms to step in and provide the same or similar financial services," the report said.
Insurance companies could be asked for data on their off-balance-sheet positions, which could help the council gauge the true size of the firm. Insurers may also be required to give information on how many shares of other companies and municipal bonds they own--data that could allow regulators to judge how tied the insurer is to other firms.
Regulators also could assess how hard it would be to dismantle an insurance firm by studying the number of regulators involved and the complexity of the company. Geithner said in 2009 that he changed his mind on whether to rescue AIG after recognizing how much chaos a failure could cause.
Hedge Funds
The list suggests new document requirements so the council could see how much capital asset managers have to support their investment positions, the complexity of hedge funds' portfolios, and the amount of leverage private-equity funds use. Another proposed form would include stress tests of asset managers.
Agencies, including the Securities and Exchange Commission, are also proposing to step up demands for information from firms such as hedge funds, which SEC Chairman Mary Schapiro in November said have been "out of sight and were unknown to financial regulators and the public."
The FSOC staff report's considerations "are meant to provide context and an initial filter" for regulators as they consider individual firms, the document said.