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Positioning for

change
A roadmap for implementing
US financial reform
At Ernst & Young Financial Services, we help our asset management, banking,
capital markets and insurance clients manage change and drive growth. It’s how
we make a difference.
With the passage of this historic US financial
reform legislation, executives can expect a
major transformation in the world in which
financial services firms operate. This law
will affect nearly every facet of the
investing landscape.

In such an environment, you need an advisor


you can trust. Ernst & Young’s dedicated
financial services professionals stand
ready to help you develop a roadmap to
implementing US financial reform.

Positioning for change A roadmap for implementing US financial reform 1


Fasten your seatbelts
The Dodd-Frank Act and the new financial services landscape

On 21 July 2010, US President Barack will be increased, with the largest and funds and private equity funds by banking
Obama signed into law the Dodd-Frank Wall most interconnected financial firms most entities subject to de minimis limits allowing
Street Reform and Consumer Protection significantly impacted. Prescriptions include bank investments in hedge funds and private
Act (Dodd-Frank Act). The Dodd-Frank a stress-testing regime requiring annual equity funds of no more than 3% of their
Act follows more than a year of intensive stress tests by supervisors of systemically tangible common equity in all such funds
negotiations among US legislators and important financial firms, with the combined or 3% of the fund’s total ownership
represents a far-reaching overhaul institutions themselves required to conduct interest. Certain derivatives activities,
of the framework for US financial stress tests semi-annually and an annual including equity derivatives, are required to
stress-testing requirement for all federally be “pushed out” of insured banks into non-
services, including the US operations
regulated financial companies with assets bank affiliates.
of foreign financial firms. The Dodd-
greater than $10 billion. In addition, federal
Frank Act includes the following • A regulatory framework for OTC derivatives
banking agencies are required to develop
provisions. transactions. OTC derivatives, along with
and issue countercyclical capital standards
dealers and other significant participants,
for both holding companies and insured
• A new regime for systemic risk are subject to regulatory oversight, including
depository institutions. Large bank holding
regulation and prudential supervision requirements to clear certain standardized
companies (BHCs) and NBFCs will be subject
of all systemically important financial contracts through central counterparties,
to heightened capital and other prudential
firms. The Dodd-Frank Act establishes a capital, margin, reporting and record keeping,
standards, and regulators will be able to
10-member Financial Stability Oversight with standards to be developed by the
restrict the activities and growth of
Council (FSOC) and extends consolidated relevant banking regulators along with the
such companies.
prudential supervision and regulation by the SEC and the CFTC. Oversight of derivatives
Federal Reserve to all systemically important • More comprehensive supervisory remits. activities will be shared by the CFTC and SEC.
financial firms and major market utilities These entail an overall strengthening of Implementing regulations will be promulgated
not supervised by the Commodity Futures prudential supervision that extends Federal to define which institutions are covered, as
Trading Commission (CFTC) or Securities and Reserve Bank (FRB) examination and well as oversight and reporting requirements.
Exchange Commission (SEC). While those enforcement authority over holding company
• A registration mandate for advisors to
non-bank financial companies (NBFCs) that subsidiaries to cover non-bank subsidiaries
larger hedge funds and private equity
will be covered have yet to be determined, engaged in activities permitted for banks
funds. Most advisors to hedge funds and
they could include large broker-dealers, and functionally regulated subsidiaries.
private equity funds with more than
hedge funds, private equity funds, asset They also extend inter-affiliate transactions
$100 million in assets under management
managers, insurance companies and other restrictions to derivatives and securities
will be required to register with the SEC
non-banks. The FSOC may require reporting borrowing and lending transactions between
and be subject to SEC regulatory oversight
from any banking organization or NBFC in insured depositories and affiliates. Finally,
(venture capital funds will be exempt, with a
order to determine whether it poses a risk they extend bank single-borrower limits and
definition of such funds to be provided by the
to financial stability. This could lead, at least create backup examination and enforcement
SEC within a year of enactment). However,
initially, to extensive reporting from a wide authority for federal regulators in cases
advisors with less than $150 million in assets
spectrum of financial firms. where the primary regulator fails to act.
under management in the US whose only
• Requirements for heightened prudential • Limitations on the activities of banks — the clients are private funds will remain exempt
standards. Prudential standards for capital, “Volcker Rule.” Limitations are imposed on from registration, subject to record-keeping
liquidity, leverage and risk management proprietary trading and investments in hedge and reporting requirements to be established

2
by the SEC. Organizations that are required authority is established under which the • Changes to the regulation of the insurance
to register will need to establish a formal Secretary of the Treasury may appoint the industry. While the law retains the primacy
compliance policy and a framework that Federal Deposit Insurance Corporation (FDIC) of state regulation of insurance and does
encompasses (1) the treatment of conflicts, as receiver for a systemically important non- not introduce any fundamental reform of
(2) the hiring of a chief compliance officer, bank firm that has failed or is in danger of insurance regulation, the Federal Insurance
and (3) testing, reporting and inspections failing. Large banking organizations and non- Office is established within the Department
by the SEC. Advisors to smaller funds bank financial firms are required to prepare of the Treasury as a coordinating and
may also be subject to record-keeping and resolution plans (so-called “living wills”) advisory authority. The insurance industry
reporting requirements. describing how they would wind down their is represented on the FSOC, and insurance
operations in an orderly manner if they were firms may face enhanced supervision as
• Additional disclosures and “skin in the
to face severe financial distress or failure. systemically significant institutions or, for
game” for securitization. Securitization
those insurance companies that are savings
markets and activities are subject to • Additional assessments for systemically
and loan holding companies, be subject to a
increased regulation, including greater significant firms. FDIC deposit insurance
new supervisory regime.
disclosures. Issuers and originators/sellers is raised for depository institutions with
of assets to a securitization will be required assets greater than $10 billion. Additional • A stronger SEC. Three provisions are
to retain a minimum of 5% of the underlying assessments may be imposed on larger expected to strengthen the SEC’s regulatory
credit risk. firms to help fund the FSOC and additional role. First, the SEC’s budget will be doubled
supervisory responsibilities of the FRB, as over the next five years. In addition, the SEC
• A new consumer protection regulatory
well as to potentially cover resolution costs will be able to tap a new $100 million SEC
framework. A Bureau of Consumer Financial
for failed institutions. “reserve fund” to supplement its budget
Protection (BCFP) is established as an
and facilitate long-range planning and
independent agency within the Federal • Reforms to compensation practices.
commitments. This fund will be replenished
Reserve with broad rule-making, examination Compensation practices are also addressed
in $50 million annual increments out of SEC
and enforcement authority over savings, through a range of measures requiring
fee income. Second, the SEC will be able to
credit and deposit products and the firms that expanded disclosure, increased corporate
use its existing authority to recruit certain
provide them. governance oversight, “say-on-pay”
professionals with “specialized knowledge
shareholder votes and extended proxy rights.
• Enhanced investor protection measures. of financial and capital market formation
Further regulatory guidance will follow with
Investor protection is enhanced through or regulation, financial market structures
respect to incentive-based compensation
additional rule-making and enforcement or surveillance, or information technology.”
schemes, as the Dodd-Frank Act mandates
powers for the SEC, and the SEC is required This is intended to assist the SEC’s ongoing
regulation of compensation at financial
to conduct a study evaluating the standards efforts to build greater securities industry
institutions to prohibit arrangements that
of care applicable to brokers, dealers and experience. Last, enhanced “whistleblower”
encourage excessive risk taking.
investment advisors. The SEC is also protection rewards individuals who
granted the authority to impose new • Bank regulatory consolidation. The Office provide government agencies with original
fiduciary standards. of Thrift Supervision is abolished and its information that leads to successful
functions are allocated among the FRB enforcement cases between 10% and 30% of
• A resolution framework for systemically
(e.g., holding companies), the Office of the any settlement in excess of $1 million.
significant firms and the development of
Comptroller of the Currency (OCC) (e.g.,
“living wills.” To address “too big to fail”
federal savings banks) and the FDIC (e.g.,
and other concerns, an orderly resolution
state savings banks).

Positioning for change A roadmap for implementing US financial reform 3


Get in gear
Take a proactive approach by allocating sufficient resources
to evaluate the challenges ahead

The full impact of these reforms will occur many firms are evaluating the competitive,
over an extended period, with considerable operational, tax and other business
post-enactment rule making necessary implications of the reform agenda and are
by all the agencies to clarify the practical preparing their strategies to approach the
impact of many of the statutory provisions wide-ranging requirements in the law soon.
and otherwise implement the new regime. Initiatives to comply with regulatory demands
Further, the law requires numerous studies to are already taxing firms’ resources, and
be conducted, generally over the next year these demands will grow considerably as
or two, which could lead to refinements or the new landscape takes shape. Many firms
more substantial changes to the framework have already mobilized program resources
over time. Notwithstanding the remaining to assess the impact of the reforms on their
uncertainties, regulators are already businesses and operations and to identify
pursuing many aspects of the reform agenda opportunities to leverage existing initiatives
under their existing authorities. Moreover, and recent enhancements.

4
Systemic risk regulation and regulatory structure
FSOC responsible for monitoring systemic risk and making recommendations to Federal Reserve for prudential supervision of systemically significant firms
Regulators

Enhanced powers for the Federal Reserve as supervisor for New resolution OCC will retain supervision of SEC and CFTC jointly responsible for OTC
systemically significant NBFCs, as designated by the FSOC; process for national banks; FDIC of state derivatives regulation; SEC acquires jurisdiction
independent BCFP established within the Federal Reserve NBFCs, managed banks; OTS is abolished over hedge funds and private equity funds; SEC
by FDIC also gains investor protection powers

Corporate governance practices


Governance

• Requirement for board-level risk committee for larger BHCs and designated NBFCs
• Requirement for independent compensation committee for issuers
• Proxy access for shareholders
• Shareholder “say-on-pay” on executive compensation; additional controls and disclosures with respect to compensation practices

Enhanced prudential standards Restrictions on activities


• Imposes heightened capital, leverage and liquidity requirements • Banks limited to 3% of their own Tier 1 capital as principal investments in
standards
Banking

• Requires “living will” resolution plans hedge funds and private equity funds; banks will still be able to manage
• Prohibits TruPs as part of Tier 1 capital for banks with assets ≥$15b such funds
• Sets an enhanced risk management focus — risk governance, counterparty • Certain derivatives deals restricted – banks prohibited from entering contracts
reporting, stress testing, compensation practices for riskier commodities, stocks and non-investment-grade backed CDS;
interest rate and FX swaps are among types that can be retained
OTC derivatives

Joint regulation of OTC derivatives market by SEC and CFTC


• Central clearing for all standard OTC contracts; exchange trading for all cleared OTC contracts, where it exists
• Customized swaps subject to punitive capital requirements and reporting to regulated central repositories
• Capital, margin, reporting and record-keeping requirements for all swap dealers and major swap participants
• Commercial end-users exempt from most requirements

Consolidated federal regulation and enforcement of consumer financial protection Investor protection
Consumer and

• BCFP to be housed within (but independent from) the Fed; will assume primary federal responsibility for consumer • SEC is granted additional examination
investor

protection regulation and absorb existing powers from current bank regulators and enforcement powers, including
• Will assume rule-making, examination and enforcement powers for banks with assets > $10b, mortgage brokers, power to impose fiduciary duties on
credit unions and certain other non-bank financial firms broker-dealers
• States retain power to impose and enforce more restrictive laws and regulations

Insurance companies Hedge funds and private Credit rating agencies Securitization
• Federal Insurance Office established equity funds
• Increased liability for ratings • Issuers, packagers of asset-backed
to coordinate and advise on • Most funds with AUM ≥$100m and regulation by the SEC of securities must retain some percentage
Other

regulatory policy; insurance industry must register with the SEC as business practices of unhedged credit risk on their balance
representation on the FSOC Investment Advisers, with resulting sheets (e.g., 5%); regulators have
reporting, record-keeping and discretion to lower this percentage for
compliance requirements certain low-risk assets

Positioning for change A roadmap for implementing US financial reform 5


Though it will be a journey, there are key
issues to consider at the outset

While the precise impact of the law will vary • Wide-ranging operational impacts stemming • Collection, assessment and reporting of
from firm to firm based on industry sector, from the need to develop and sustain enterprise-wide risk information
legal entity structure, tax posture and recovery and resolution plans may lead some • Practices to identify and respond to emerging
business model, all firms need to re-evaluate financial conglomerates to rationalize aspects risks
both short- and longer-term strategies. The of their complex operational, funding and
legal entity structures. • The law raises the governance bar even
following are some key issues the industry is
higher, requiring risk management to adapt
likely to face. • Firms will be required to analyze the tax to higher standards for enterprise-wide risk
Business implications of the business, operational governance and reporting to support and
and structural changes and to consider inform the board-level risk committee, now a
• Banks will face limitations on certain tax optimization strategies and the impact required governance body for public financial
activities, including restrictions on proprietary of each on their current and future tax firms. In addition, risk management functions
trading and certain derivatives activities, models. This applies to domestic financial will be subject to an increased emphasis
as well as on the investment in, ownership organizations and to foreign-based financial on reporting and analysis with respect to
of and relationships with hedge funds and institutions with US operations. counterparty exposures, concentrations and
private equity funds. Even where not directly liquidity, including reporting to the regulators
restricted, banks can expect profit margins • Although much of the US law remains
consistent with the global goals set out by more frequently than traditional quarterly
to narrow with increased costs on derivatives financial statements, and heightened credit
trading activities, securitized products and G20 leaders, the extent and pace of US
reforms may lead foreign-based financial underwriting standards and analytics.
across many aspects of consumer banking. The establishment of sustainable ongoing
The restrictions in the banking sector may firms active in the US market to reconsider
their business models and potentially processes for data sourcing, scenario
create competitive advantages for stand- identification, modeling and governance
alone asset managers, hedge funds and migrate proprietary trading, private fund and
derivatives activities to other jurisdictions. to support the prescribed stress testing
private equity funds, potentially fuelled in requirements will also be significant.
part by an inflow of talent driven by the Conversely, legislative, tax and regulatory
more restrictive compensation practices initiatives abroad may affect how US-based • Consumer and investor protection reforms
being imposed on large banks. Moreover, firms choose to operate internationally. are likely to add new business conduct
expectations for higher capital and liquidity standards and attendant disclosure and
Governance, risk and compliance
cushions will result in an increased focus record-keeping burdens to compliance
on the allocation of capital, placing added • Banks are already experiencing challenges functions.
pressure on returns, which could lead to the as the bar is rising for risk governance
• Many firms will be newly subject to reporting
reassessment of some business models. practices, with regulatory attention focused
and compliance requirements (e.g., private
intensively on:
• Large financial institutions considered pools of capital, clearing organizations), and
• Board and senior management engagement and others will be exposed to new regulators
systemically important will likely have
accountability, particularly related to the setting and regulatory requirements (e.g., major
increased pressure on returns as they may be
of strategy and risk appetite and performance
subject to special assessments and additional participants in the swaps market, savings
monitoring
costs to (1) minimize or even avoid the associations and their holding companies,
utilization of taxpayers’ money in the event a • The organizational structure, stature and NBFCs), with attendant implications for
large financial institution fails and (2) pay for responsibilities of risk management within the their governance, risk management and
institution compliance structures and processes.
the additional responsibilities undertaken by
the government. Hedge funds and private equity funds will be

6
required to implement the record-keeping, risk regulators threatening firms’ ability • The separation of certain swap activities from
reporting and compliance frameworks under to expand: banking entities — and from expectations
the Investment Advisor Act. that certain material legal entities will have
• Business lines and control areas face an
to become more self-sufficient as part of
• The law has highlighted areas within the tax increasingly high bar for reporting to
management and regulators on aggregate
firms’ resolution and recovery planning — will
law that the Internal Revenue Service may
risk positions and concentrations, particularly require evaluation of capital and liquidity
likely scrutinize further, such as derivatives
counterparty credit exposures. adequacy at the individual legal entity
contracts, capital structures and incentive
level for key subsidiaries. These demands
compensation. Firms need to review and • Some private funds may also need to provide
will add to incentives for firms to consider
understand their current tax positions to incremental regulatory reporting to support
rationalizing their legal entity structures and
ensure their tax risk profiles are acceptable systemic risk monitoring, including information
regarding investments, leverage, exposures and
re-evaluating interdependencies between
and tax disclosures are complete.
valuation practices. legal entities.
Technology, data and operations
• Derivatives, securitization and consumer • A greater focus on liquidity is likely to force
• Greater demand on IT infrastructure and data businesses will require even more granular firms to reduce reliance on short-term
is one of the most important outcomes of the reporting and disclosures. funding, requiring significant changes to
law and current regulatory agenda. The ability funding structures.
• Operational areas will need to adjust to new
of firms to produce timely and quality reports standards for derivatives clearing and reporting. • The tax treatment of new funding structures
from data across products, business units’
• Certain updates may be required to internal tax will need to be analyzed as it may be different
legal entities and risk types will be a major
systems, models and reporting mechanisms from the treatment of the current capital
priority for regulators and will be reinforced
to ensure the tax law is being appropriately structures.
across all sectors by the incremental
considered and implemented.
regulatory reporting requirements arising • Finally, at the very time that demands for
from systemic risk monitoring. Developing Balance sheet, funding and structure capital and liquidity are increasing, their costs
and maintaining the underlying data quality, are expected to rise, driven by requirements
• Increased prudential standards with respect
data management and data governance for higher-quality capital and greater
to capital, liquidity and leverage will impact
frameworks, and building and supporting structural liquidity. Firms’ cost of funds
all systemically significant firms, with non-
reporting requirements with the necessary will depend in part on the extent to which
bank institutions likely to face the steepest
IT infrastructure to meet these demands will markets and rating agencies believe that the
climb with respect to developing their capital
be a major undertaking for many financial reforms have truly ended the era of financial
and liquidity planning and management
institutions. Regulators, who in many cases institutions that are “too big to fail,” as well
frameworks. The requirement for BHCs to
already believe that IT infrastructure at large as on the cumulative impact of regulatory
maintain countercyclical buffers, along with
complex firms has generally not kept pace restrictions on profitability. Leading rating
stress-testing requirements, will increase
with business growth, will look closely at agencies have indicated that the withdrawal
capital requirements for a broad range
the ability of firms to consistently produce of implicit government support may warrant
of institutions.
reports supported by reliable and complete downgrades of some large financial firms, but
data. In some cases, institutions may need to • Many firms’ absolute capital levels will that they are likely to delay such assessments
make certain fundamental improvements and increase, with incremental capital demands until late 2010 or early 2011.
investments in this area immediately, or arising from certain activities deemed to be
high risk, including securitizations, securities
lending and repos/reverse repos.

Positioning for change A roadmap for implementing US financial reform 7


Mapping a plan for the road ahead
Evaluating the impact on financial institutions

The magnitude of the impact will vary across or investments in private funds. At the same
industry sectors, depending on the specific time, private funds will have to contend
areas of focus within the Dodd-Frank Act and with the impact of losing this significant
the current-state “point of departure” of each investor population and the requirements of
institution. The following table highlights the registration. More broadly, changes in capital,
potential consequences of the Dodd-Frank liquidity and legal entity structures across
Act on the main industry sectors. The effects firms will have wide-reaching impacts on
of many reforms will be most acutely felt funding, with resultant tax and accounting
by the large, systemically significant NBFCs consequences. Data quality, IT and reporting
not previously subject to conglomerate impacts will be felt by most sectors, as will
prudential supervision. For BHCs and banks, the reach of the OTC derivatives regulation
existing supervisory expectations are raised and reforms to consumer and investor
even higher, with the largest BHCs subject to protection measures. Above all, the impact of
the most intensive prudential supervision and these activity restrictions and funding costs
activity restrictions. The restrictions imposed on profitability and growth may cause firms
by the “Volcker Rule” will require some to re-evaluate their strategic plans.
banks to consider longer-term options for
conforming to proscribed proprietary trading

8
Financial organization Primary federal Business and commercial Governance, risk and control Operations Balance sheet, funding
regulator activities functions and IT and structure

Proprietary trading
Consumer banking

Risk management
OTC derivatives

Securitization

Finance/tax

Legal entity
Compliance

Regulatory

Operations

structure
reporting

Liquidity
Data/IT

Capital
BHCs ≥ $50b FRB
Other BHCs OCC/FDIC
National banks OCC
State banks FDIC
Designated NBFCs FRB
Hedge funds/ private equity
SEC
funds
Asset managers SEC
Broker-dealers SEC
Insurance* N/A

Impact of Dodd-Frank Act Significant Moderate

*Savings & Loan holding companies will be subjected to prudential supervision as if they were BHCs. This may impact a number of insurance firms.

Positioning for change A roadmap for implementing US financial reform 9


Mapping a plan for the road ahead
Priorities for financial services firms

Institutions are beginning to evaluate the Key initiatives that most firms should • Begin data quality improvements and IT
impact of the law through a structured consider are: infrastructure investments
assessment of the strategic, tax and
• Strengthen the alignment of compensation • Further develop regulatory and management
operational implications for aspects of reporting
practices and risk management
their business models. This exercise should
consider immediate responses to current • Address OTC derivatives process modification • Begin to tackle hedge fund and private equity
regulatory and supervisory priorities, to support central clearing, exchange-based fund registration compliance requirements
including enhancements to risk governance, trading, capital, margin and reporting
• Develop securitization reforms
data quality, disclosure requirements, requirements
reporting and capital management and • Enhance capital management practices
• Prepare for enhanced prudential supervision,
compliance frameworks and processes; in particular at non-bank financial companies • Strengthen liquidity risk management
medium-term objectives, including aspects framework
• Develop and enhance resolution and recovery
of OTC derivatives processing that may
plans • Begin to implement the necessary steps
be dependent on the details of future rule
to meet consumer and investor protection
making and uncertain industry direction; and • Enhance risk and corporate governance
reforms
longer-term, strategic decisions, including frameworks
changes to legal entity structure. • Evaluate strategic and operational
• Analyze tax implications, disclosure
approaches to divesting proprietary trading
Firms are starting to develop and prioritize requirements and tax operational systems
positions
a set of projects in a consolidated
• Examine restructuring opportunities and
implementation roadmap to address the related impact to business and tax models
requirements of the Dodd-Frank Act.

10
1. Assess strategic and operational impact 2. Prioritize 3. Develop implementation roadmap

Firms should develop an


2010 2011 2012
integrated and prioritized plan,
Business and driven by timelines in the Act, tax Strategic and operational impact assessment
commercial implications, regulatory priorities
and project scope. Initial actions
• Growth/contraction may include:
of markets Multi-phase Compensation practices
• Top-line revenue • Compensation practices
• Margin • OTC platform enhancements
• Competition • Cross-functional preparedness Multi-phase OTC derivatives processing
• Tax optimization for FRB prudential supervision
• Talent retention for impacted non-banks
• Resolution planning Multi-phase Systemic supervision
• Risk and corporate governance
• Data quality and IT infrastructure
enhancements Multi-phase Resolution planning
• “Volcker Rule” structural
changes to proprietary trading,
Operations and IT
Governance, risk hedge fund and private equity Proprietary trading/fund investing (Volcker) Multi-phase
and control Impact assessment • Data quality, fund investments
aggregation and
• Board-level • Short-term impact Medium-term priorities include
governance
engagement • Longer-term, initiatives dependent on further Risk governance enhancements
• MIS and
• Organization strategic impact rule making:
reporting
• Resourcing and • Addressing
systems
skill sets uncertainty — • Regulatory and management Data quality and IT infrastructure Multi-phase
• Reporting
• Integration consider alternative reporting
• Strategic
• Ongoing outcomes through • Private fund registration
investment
compliance sensitivity analysis • Securitization reforms Regulatory and management reporting Multi-phase
needs
• Tax scrutiny • Capital management
• Tax models
• Liquidity risk framework
• Consumer and investor Private fund registration
compliance enhancements

Balance sheet, Securitization


funding and structure
• Capital demand
• Capital and funding Capital management
structure
• Accounting policy
• Contingent capital Liquidity risk framework
arrangements
• Divestiture
• Legal entity Consumer and investor compliance
structure requirements
• Tax treatment
• Ratings impacts
3-6 months 6-18 months 18+ months

Positioning for change A roadmap for implementing US financial reform 11


It is clear that the Dodd-Frank Act will have
far-reaching impacts throughout the financial
services industry that will require a dynamic
approach to navigating both the uncertainties
and opportunities ahead.

At Ernst & Young Financial Services,


you’ll benefit from integrated services
tailored to your business needs and an
enterprise-wide approach to implementing
US financial reform.

12
Helping you reach your
destination
Contact us

Financial Services
Carmine DiSibio +1 212 773 1673
Vice Chair and Managing Partner, carmine.disibio@ey.com
Financial Services
William Schlich +1 212 773 3233
Global Banking & Capital Markets Leader william.schlich@ey.com
Art Tully +1 212 773 2252
Global Hedge Fund Co-Leader arthur.tully@ey.com
Jeff Bunder +1 212 773 2889
Americas Private Equity Leader jeffrey.bunder@ey.com
Peter Porrino +1 212 773 8468
Global Insurance Leader peter.porrino@ey.com
Don Vangel +1 212 773 2129
Advisor, Regulatory Affairs, donald.vangel@ey.com
Financial Services
Hank Prybylski +1 212 773 2823
Advisory Leader, Financial Services lawrence.prybylski@ey.com
Global Financial Services
Risk Management Leader
Joanne Dunbar +1 212 773 2727
Transaction Advisory Leader, joanne.dunbar@ey.com
Financial Services
Kurt Neidhardt +1 212 773 2283
Tax Leader, Financial Services kurt.neidhardt@ey.com
Susan Cote +1 212 773 8700
Assurance Leader, Financial Services susan.cote@ey.com

Public Policy
Beth Brooke +1 202 327 8050
Global Vice Chair — Public Policy, beth.brooke@ey.com
Sustainability and Stakeholder Engagement
Les Brorsen +1 202 327 5968
Americas Director, Office of Public Policy les.brorsen@ey.com
Bridget Neill +1 202 327 6297
Director of Regulatory Policy bridget.neill@ey.com
Mary Frances Pearson +1 202 327 8395
Director of Federal Relations maryfrances.pearson@ey.com

Positioning for change A roadmap for implementing US financial reform 13


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