Leverage in Nonbank Financial Intermediation (NBFI): Overview of consultation responses and changes to the report to address them

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On 18 December 2024, the FSB published a consultation report on Leverage in Nonbank Financial Intermediation. The objective of the consultation was to gather stakeholder feedback on the proposed recommendations to address financial stability risks arising from leverage in nonbank financial intermediation.

The FSB received 36 responses to the consultation, which ended on 28 February 2025. The majority of responses came from asset managers and capital market and other financial market associations mainly based in the United States and Europe.

This note summarises the feedback received on the consultation report and sets out the main changes made to the final report in order to address them.

FSB publishes recommendations to address financial stability risks created by leverage in nonbank financial intermediation

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Ref: 13/2025

  • Leverage recommendations give authorities flexibility to select, design and calibrate measures that best address financial stability risks created by NBFI leverage in their jurisdiction, while considering potential adverse effects.
  • NBFI progress report highlights the FSB’s shift from policymaking to monitoring NBFI vulnerabilities, addressing data challenges, sharing members’ insights and policy approaches, and evaluating policy implementation.
  • A Nonbank Data Task Force, chaired by FSB Chair Andrew Bailey, is assessing ways to address key nonbank data challenges through a test case on leveraged trading strategies in sovereign bond markets.

The Financial Stability Board (FSB) today published three reports related to its work programme to enhance resilience in nonbank financial intermediation (NBFI).

Final policy recommendations to address financial stability risks created by NBFI leverage

The recommendations on NBFI leverage, which have been delivered to the G20, set out an integrated approach for addressing financial stability risks created by NBFI leverage. Under this approach, authorities should identify such risks and have appropriate policy measures in place to address the risks they identify. The recommendations provide authorities with flexibility to tailor their policy responses to their jurisdiction-specific circumstances. This includes selecting, designing, and calibrating policy measures – or combinations of measures – that address financial stability risks, while considering potential adverse effects. Authorities will share their policy responses, for example, through FSB supervisory discussions.

The recommendations are directed at FSB member authorities and focus on markets, entities, and activities where NBFI leverage poses financial stability risks. These risks vary across jurisdictions. The FSB and standard-setting bodies (SSBs) will undertake further work to support and assist authorities in applying the recommendations. This work will begin with supervisory discussions among authorities and, later this year, members will consider whether to pursue follow-up work on certain recommendations, including defining the potential scope of that work.

The recommendations reflect feedback from a public consultation. In particular, the FSB acknowledges the high degree of heterogeneity of nonbanks; that leverage in some NBFI segments is relatively limited and is not likely to pose financial stability risks; the differences between banks and various types of nonbanks, which have motivated different regulatory approaches; and that certain leveraged activities by nonbanks can facilitate hedging, enhance efficiency and support liquidity in financial markets.

Annual NBFI progress report

The 2025 NBFI Progress Report notes that the work carried out to date largely completes the original policy elements of the FSB’s NBFI work programme, which were agreed upon in response to the March 2020 market turmoil. The FSB’s work will now shift from policymaking to assessing vulnerabilities, addressing data challenges, sharing members’ policy insights, and evaluating the implementation and impact of reforms.

Workplan to address nonbank data challenges

In carrying out the NBFI work programme, the FSB identified several data challenges that hinder authorities’ ability to effectively assess vulnerabilities in the nonbank sectors. To address this, the FSB has established the Nonbank Data Task Force (NDTF), chaired by the FSB Chair, Andrew Bailey. The NDTF has three objectives:

  1. Improve the ability of FSB member authorities to identify and assess vulnerabilities stemming from nonbank sectors.
  2. Improve the ability of authorities to assess and calibrate policies to mitigate financial stability risks stemming from nonbank sectors.
  3. Explore whether and how authorities could share information, including data, to mitigate significant financial stability threats.

As part of this work, the FSB has launched a test case on leveraged trading strategies in sovereign bond markets to assess how much progress can be made in addressing key nonbank data challenges. This area was chosen due to its critical importance to financial stability and the key data challenges it presents, including some with a significant cross-border dimension.

At the request of the South African G20 Presidency, the FSB is submitting a workplan to address nonbank data challenges, which outlines how the NDTF’s work will be structured and the next steps. The FSB will publish a report on the NDTF test case by mid-2026, detailing ways to address the identified data challenges. Following this, the FSB will determine whether further work should be undertaken in other areas.

In parallel, the FSB has also decided to conduct an analytical deep dive on vulnerabilities in private credit, which will include the identification of data challenges in this area.

Notes to editors

The FSB published in November 2020 a Holistic Review of the March Market Turmoil, which laid out a comprehensive and ambitious work programme for strengthening the resilience of the NBFI sector while preserving its benefits. This work is being carried out within the FSB as well as by its member SSBs and international organisations, to ensure that relevant experiences and perspectives are brought to bear.

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Andrew Bailey, Governor of the Bank of England. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.

Public webinar on the FSB’s recommendations to address leverage in nonbank financial intermediation

The FSB held a webinar to present its recommendations to address risks arising from leverage in nonbank financial intermediation on Wednesday 9 July, hosted by the Bank of England

On Wednesday 9 July, the FSB published its recommendations to address financial stability risks arising from leverage in nonbank financial intermediation. The recommendations follow a public consultation and incorporate the feedback received from it.

 The webinar was hosted by Andrew Bailey, Chair of the Financial Stability Board and Governor of the Bank of England. He will be joined by:

  • Cornelia Holthausen, Director General, DG Macroprudential Policy and Financial Stability, European Central Bank
  • Sarah Pritchard, Executive Director, UK Financial Conduct Authority
  • John Schindler, Secretary General, Financial Stability Board

 This webinar was open to all.

FSB examines vulnerabilities in non-bank commercial real estate (CRE) investors

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Ref: 12/2025

  • FSB identifies liquidity mismatches, leverage, and valuation opacity as the main vulnerabilities in real estate investment trusts (REITs) and property funds.
  • Report also notes complex interlinkages between banks and non-bank CRE investors, which increases the potential for spillovers from CRE market shocks.
  • Report underscores the importance of closing data gaps to enhance authorities’ ability to monitor risks from non-banks’ involvement in CRE.

The Financial Stability Board (FSB) today published a report analysing the vulnerabilities in non-bank commercial real estate investors. The report builds on the findings of the 2024 FSB report on interest rate and liquidity risks in the financial system, which identified non-bank CRE investors – comprising real estate investment trusts (REITs), property funds, and other non-bank mortgage lenders – as one of the entity types vulnerable to higher interest rates.

Data from FSB members suggests banks and nonbanks collectively provided at least $12 trillion in equity and debt financing to CRE in 2023. While banks remain the main source of such financing, non-bank investors – particularly property funds and REITs – play a significant role in some jurisdictions. The report identifies three main vulnerabilities in these investors:

The report also highlights the complex interlinkages between banks and non-bank CRE investors. Banks are the main debt providers to, and can also invest in, REITs and property funds. Banks may also have common asset exposures to these investors, which increases the potential for shocks to the CRE market spilling over to the banking sector. A more complete overview of these interlinkages is limited by considerable data gaps, despite improvements in recent years. Closing some of these gaps would enhance authorities’ ability to monitor risks.

So far, the global financial system has weathered the recent adverse developments in the CRE market. This can be attributed to the market’s heterogeneity; lower loan-to-value levels than previous episodes of stress; and the ability of some distressed borrowers to refinance. However, ongoing monitoring of the market is warranted given the more volatile performance of CRE exposures compared to other assets, structural shifts in demand, and the effects of extreme weather events and new energy efficiency standards in some jurisdictions.

Notes to editors

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Klaas Knot, President of De Nederlandsche Bank. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.

Vulnerabilities in Non-bank Commercial Real Estate Investors

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Ongoing monitoring of the commercial real estate (CRE) market is warranted given the more volatile performance of CRE exposures compared to other assets, structural shifts in demand, and other factors.

The commercial real estate (CRE) market has experienced significant stress in recent years. Certain segments, such as offices and retail space, experienced weak demand since the COVID-19 pandemic due to the shift to home working. Stress was also caused by the increased borrowing costs that took place in 2022 and 2023 in a number of advanced economies. The 2024 FSB report on the confluence of interest rate and liquidity risks in the financial system identified, among other things, non-bank CRE investors – comprising real estate investment trusts (REITs), property funds, and other non-bank mortgage lenders – as one of the entity types vulnerable to higher interest rates.

This report examines the main vulnerabilities associated with non-bank CRE investors, particularly REITs and property funds. It provides an overview of global CRE markets, looking at definitions, market size, and recent performance trends, as well as exposures and interlinkages among market participants. The report also identifies data gaps that hinder effective monitoring of non-banks’ involvement in CRE at a jurisdictional and global level.

See more charts by selecting from the dropdown menu

Source: FSB

Changes since 2018

2018 = 100

The trends for TR coincide with the high inflation taking place since November 2021 and is displayed on the left axis for some panels.

Source: FSB member submissions; JLL Research.

Source: MSCI (2024), Real Estate Market Size, July.

FSB Regional Consultative Group for the Americas meets in Nassau

The Financial Stability Board (FSB) Regional Consultative Group for the Americas met on 17 June in Nassau, hosted by the Central Bank of the Bahamas.

The meeting, which brings together senior officials from central banks, financial authorities and regulatory bodies in the region covered:

  • Global financial market developments and the outlook for financial stability in the region.
  • Progress toward achieving the goals of the G20 Roadmap to enhance cross-border payments.
  • Recent developments and approaches to monitoring vulnerabilities in the non-bank financial intermediation sector.

Members thanked the out-going chairs, Tiff Macklem and Kenneth Baker, and discussed potential future topics for collaboration and exploration.

FSB Regional Consultative Group for Sub-Saharan Africa meets in Livingstone

The Financial Stability Board (FSB) Regional Consultative Group for Sub-Saharan Africa (RCG SSA) met on 17 June in Livingstone, hosted by the Bank of Zambia.

Members exchanged views on financial vulnerabilities at the global and regional level; the impact of extreme weather events in Sub-Saharan Africa and how the private and public sectors can best prepare for such events; and progress on the G20 Roadmap on cross-border payments, , including challenges faced by both the public and private sector to effect tangible improvements in payment arrangements.

Members also shared recent regional developments in crypto-assets and stablecoins, including steps to implement the FSB’s regulatory framework.

FSB Plenary meets in Madrid

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Ref: 11/2025

The Financial Stability Board (FSB) Plenary met in Madrid on 11 June to discuss key priorities for global financial stability.

The Plenary confirmed the appointment of Andrew Bailey, Governor of the Bank of England, as the next FSB Chair for a three-year term beginning on 1 July 2025. Plenary members thanked Klaas Knot for his leadership and guidance in steering the work of the FSB over the past four years.

Members discussed vulnerabilities in the global financial system, issues related to non-bank financial intermediation (NBFI), crypto-assets, climate-related financial risks, and resolution.

Financial stability outlook

Financial markets have largely stabilised following the sudden and severe spike in market volatility in April 2025 that followed the announcement of US trade tariffs and retaliatory action by some other jurisdictions. The episode illustrated how elevated asset prices, which were highlighted as a vulnerability in recent FSB work, can be susceptible to a sudden unwind in the event of an external shock. Plenary members noted that financial markets remained resilient through this episode, despite much higher trading volumes. Nevertheless, members cautioned that there remains a risk of further market strains given the uncertainty about the economic outlook and the potential for unexpected policy changes.

Members also highlighted key vulnerabilities requiring attention in the coming months. Debt levels, in particular government debt, are high, and debt dynamics are projected to worsen in a number of jurisdictions. Potential vulnerabilities from leverage and liquidity mismatches in parts of the NBFI sector remain, while operational failures can impact critical parts of the financial system. Growing interlinkages between crypto-asset markets and the financial system and increasing use cases for stablecoins warrant closer monitoring.

Non-bank financial intermediation

The Plenary reviewed the FSB’s upcoming recommendations on NBFI leverage, which will be delivered to the G20 in July, and discussed the medium-term work plan aimed at enhancing resilience in NBFI.

Taking forward the FSB’s work programme to enhance the resilience of NBFI depends heavily on reliable data. In the course of its work, the FSB has identified several data challenges that have hindered the effective assessment of nonbank sector vulnerabilities by authorities. The FSB has set up a high-level task force, the Nonbank Data Task Force – chaired by incoming FSB Chair Andrew Bailey – to address these challenges. The Plenary received an update on the Taskforce’s work and approved a near-term focus on use of leverage in government bond markets.

The FSB will publish a report in July detailing progress on its overall NBFI work programme, and a report outlining its workplan to address nonbank data challenges.

FSB work programme updates

The Plenary discussed progress on the FSB’s work programme for 2025 and received updates on key initiatives from its committees. 

The Plenary reviewed the status of the FSB Roadmap for addressing climate-related financial risks, on which the FSB has been asked to provide a progress report to the July G20 meeting. As part of annual work programme discussions, FSB members will continue to evaluate how the analysis of topics, such as physical risks and gaps in insurance coverage, may contribute to a better understanding of financial stability risks.

Members received updates on the implementation of the FSB’s global recommendations and the ongoing crypto thematic peer review, which will be delivered to the G20 later this year.

The Plenary also discussed progress on the Resolution Steering Group’s key initiatives and future priorities. Members expressed support for ongoing efforts to strengthen resolution effectiveness and enhance crisis preparedness.

Notes to editors

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Klaas Knot, President of De Nederlandsche Bank. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.

How is the water? Continuing our work to preserve financial stability

Remarks by FSB Chair, Klaas Knot, at the Bank of Spain and CEMFI Fifth Conference on Financial Stability, Madrid, 12 June 2025.

The views expressed in these remarks are those of the speaker in his role as Chair of the FSB and do not necessarily reflect those of the FSB or its members.

Thank you. I want to start by telling you a little story. Some of you may know it.

There are these two young fish swimming along and they happen to meet an older fish swimming the other way. The older fish nods at them and says “Morning, boys. How’s the water?” And the two young fish swim on for a bit, and then eventually one of them looks over at the other and says “What the hell is water?”

This parable was famously used by the American writer David Foster Wallace in a commencement speech in 2005. Now, just like Wallace, I don’t plan to present myself here as the wise, older fish explaining to you what water is. The point of the fish story is merely that, like he said: ‘the most obvious, important realities are often the ones that are hardest to see and talk about.’

Now, Wallace was speaking to a class of graduates about the benefits of a liberal arts education in life. To have his idea being used by some central bank technocrat at a conference on financial stability would probably be his worst nightmare come true. But although it may seem a stretch, I think his idea applies to our world too. Because financial stability is an obvious and important reality. Its impact is universal. Financial stability affects households, businesses, governments—and ultimately, the trust that underpins our economies. It’s the basis of everything in economic life.

Because of its universal impact, financial stability seems like a natural state. We take out our phone and we pay. And the bread that we buy costs the same as it did last week. And when we wake up in the morning our savings are still in our bank account. Financial stability is something that seems to be just there, unconditionally. But it really isn’t. It is something we must continuously work for. It demands vigilance, coordination, and above all, the political will to act before the crisis hits. I know that you are aware of this. But many people tend to forget.

As this is my last address in my capacity as Chair of the FSB, let me take this opportunity to look back a bit, take stock. And ask: where do we stand? How is the water?

In truth, it has been anything but calm. Over the past years, we have experienced quite some waves in the financial system: the dash for cash during the onset of the Covid pandemic, the commodity market turmoil following the Russian invasion of Ukraine, the failure of Archegos Capital Management in March 2021, and the market volatility associated with the recent trade tariff announcements. Central banks had to intervene in some of these episodes to support market functioning and the supply of credit to the economy. And in each case, parts of the non-bank financial sector played a central role in amplifying the stress.

Non-bank financial intermediation, or NBFI, has grown into a critical part of the financial system. Its rise has been driven by regulatory shifts, search for yield, technological innovation, and demographic trends leading to asset accumulation.

The NBFI sector brings real benefits. NBFIs offer a diversified source of funding and much needed competition for banks. But they also have vulnerabilities—liquidity mismatches and the inability of some market players to prepare for them, leverage, and growing interconnectedness with banks. Historically, regulation of this sector focused on investor protection, market integrity, and other mandates. But those don’t fully capture the systemic risks. We needed a financial stability lens.

That’s what the FSB brought to the table. Our work to date has included policy recommendations to enhance money market fund resilience, to address structural liquidity mismatch in open-ended funds, and to enhance liquidity preparedness for margin calls. Later this month, we will deliver policy recommendations to the G20 to address financial stability risks arising from leverage in NBFI.

Have we made a difference? The recent bout of tariff-related volatility in global markets could serve as a test. We saw a global sell-off in equity markets and historic trading volumes. Typical correlations between certain asset classes broke down. We saw some deleveraging and large margin and collateral calls. Yet – the system held. That is encouraging. But let’s be honest: we can’t credit our reforms just yet. Because the FSB’s recommendations have not yet been implemented in full. And recommendations alone don’t reduce systemic risk. Implementation does. That means authorities must not only put them into national laws and regulations, they must also have the capacity to operationalise them.

One of the biggest challenges we face in NBFI is data. We need better data. More data. And better use of that data. There is a reason why the non-bank sector was formerly called “shadow banking”. It’s opaque. There are gaps. And those gaps mean we often don’t see the vulnerabilities—until it’s too late. The quality and timeliness of non-bank data are essential for identifying and assessing vulnerabilities and for designing and calibrating effective policies. We must address these data challenges. We can’t keep relying on crises to reveal what we should have seen coming.

That’s why a high-level group within the FSB is now exploring how to close those data gaps—to support risk monitoring, policy design and implementation, and cross-border cooperation.

And let’s be clear: we can’t just copy-paste banking rules onto the NBFI sector. It’s too diverse and different from banks. We need to look at both non-bank entities and activities. But our goal should be clear: a level playing field across the financial system. Not by weakening bank rules—but by strengthening the resilience of the non-bank sector.

Which brings me to the banking sector. During my tenure as FSB Chair, we witnessed something unprecedented: the failure of a global systemically important bank. The demise of Credit Suisse, together with the failure of three US regional banks, was a stark reminder that bank failures are not relics of the past. It brought lessons for banks and financial authorities. In some areas, our work to make the banking sector more resilient is not yet complete. Take the final Basel III standards. These are designed to strengthen the resilience of banks to withstand losses. And yet—they still have not been implemented in many jurisdictions. The Credit Suisse case also highlighted that more than 15 years after the Global Financial Crisis, authorities still face challenges in dealing with failing banks.

So yes, we’ve made progress. But we’re not done. And in the meantime, we must protect what we’ve already built.

Because let’s not forget: during all the recent episodes of financial stress the banking system held up. In fact, during the pandemic, banks acted as shock absorbers. Not shock amplifiers. They absorbed losses. They kept credit flowing. They helped keep the economy afloat. That’s no small feat.

And I believe that is largely thanks to the reforms we put in place after the global financial crisis. The years of hard work. The tough decisions. The commitment to resilience.

But now, more than 15 years later, we’re hearing familiar calls again—for deregulation. But also calls for simplification. And let me be clear: those two are not the same.

I understand the desire to simplify. Banking regulation and supervision has become overly complex. Over the past 15 years, a great deal of regulation has been introduced from various angles —global, EU, national. Micro and macro. New risks added, old ones rarely removed. There’s overlap. There’s friction. And yes, sometimes, there’s a lack of supervisory proportionality for smaller institutions. That’s worth looking into.

But keep in mind that, beyond some point, simple rules are less risk-sensitive. And that means they have to be stricter. You want simpler rules? Sure, but those rules must then be calibrated at a more prudent level. That is the general thinking behind the standardised approach of Basel III. That is also the thinking behind the leverage ratio.

Most importantly, what we must avoid is confusing simplification with deregulation. Deregulation means effectively lowering buffers by relaxing the rules. That would both reduce resilience in the banking system and increase the likelihood of financial crises. We cannot afford to undo the progress we have made. Especially not now, in this time of unusually high uncertainty, both on the economic and political front. That would be a big mistake. As the late Rudiger Dornbusch used to say: ‘The crisis takes a much longer time coming than you think, and then it happens much faster than you would have thought.’

Which brings me to my next point. The developments in both the bank and non-bank sectors are unfolding against a backdrop of major structural shifts—shifts that could reshape financial stability as we know it. I am talking here about technology, about payments, and climate risk.

Technological innovation is transforming the financial sector. It’s adding new layers of complexity. And it’s doing so at speed.

The period leading up to the 2008 Global Financial Crisis was marked by balance sheet expansion and financial product innovation. But over the past 15 years, the focus has shifted toward technological innovation. The FSB has been watching this closely. It’s our job to harness the benefits while mitigating the risks.

And yes, the benefits are real. Technology has made financial services faster, more accessible, more efficient. And in some areas, like AI, we have only started to see its full impact. But it also brings new risks. Why? Because of the speed and scale of adoption. For example in cyberattacks. Because of the growing interconnections with the traditional financial system. Because of the concentration of services in a few key providers.

Technology creates new interdependencies. And it can accelerate the pace at which a crisis unfolds. Technological innovation is perhaps most visible in the payments space, where new platforms and digital assets are rapidly reshaping how value moves across borders and between users.

These dynamics are most visible in crypto-assets. This fast-growing market has seen more than its fair share of bankruptcies, liquidity crises and outright fraud, even as its links with traditional finance continue to grow. At the FSB, we have long maintained that crypto does not yet pose a systemic risk, but recent developments suggest we may be approaching a tipping point. Barriers for retail users have dropped significantly, particularly with the introduction of crypto ETFs. The interlinkages with the traditional financial system continue to grow. Stablecoin issuers, for example, now hold substantial amounts of U.S. Treasuries. This is a segment we must monitor closely.

The crypto ecosystem will continue to evolve—and so must our regulatory frameworks. Jurisdictions are actively developing these, and the FSB’s recommendations offer a common foundation. This is especially important given the inherently cross-border nature of crypto. Effective implementation must extend beyond the G20, supported by strong regulatory and supervisory cooperation.

Now, part of crypto’s rise can be traced to the shortcomings of cross-border payments. This is a complex, technical issue. But solving it has real-world benefits—for people, for businesses, for economies. This is the goal of the G20 Roadmap for Enhancing Cross-Border Payments. The aim of the roadmap is to bring about cheaper, faster and more transparent and inclusive cross-border payment services for the benefit of citizens and businesses worldwide.

We’ve made progress. The FSB, the CPMI, and others have done a lot of work. However, our goals are ambitious. And while they have driven changes by both the private and public sectors, we continue to see significant challenges, particularly in certain regions and payment corridors. As we move toward crafting a strategy for the next phase of work, we are seeking to clarify the issues that continue to impede progress. We will continue to work with the private sector to get it done.

Next to technology and payments, we face another growing challenge—one that’s no longer on the horizon, but right at our doorstep. I’m talking about climate change. Now, climate change may originate outside the financial sector—but its impact on financial stability is very real.

Extreme weather events are becoming more frequent. And as they occur, the risks to financial systems continue to rise. These events test the ability of financial institutions to manage risk and maintain services—especially in the most vulnerable regions. That’s why we must keep strengthening risk management practices. And why we must build resilience—across the entire global financial system.

The FSB’s Climate Roadmap, launched in 2021 and endorsed by the G20, gives us a coordinated path forward. It focuses on four key areas: firm-level disclosures, data, vulnerability analysis, and regulatory and supervisory tools.

These four pillars are not standalone. They’re connected. They build on each other.

For example: consistent, reliable corporate disclosures are the foundation. They help close data gaps. They help firms—and authorities—understand climate-related risks. Better data leads to better analysis. And better analysis leads to better policy.

And we are making progress. More jurisdictions and companies are adopting climate-related disclosures. New global standards on sustainability assurance are boosting trust in those disclosures. Tools like climate risk dashboards and scenario analyses help us understand vulnerabilities. International bodies are issuing guidance on how to integrate climate risks into existing regulatory and supervisory frameworks. And across the global financial community, we’re seeing knowledge shared, capacity built, and good practices identified.

But let’s be honest—challenges remain. Especially when it comes to implementation. The groundwork is there. But now, the focus must shift to action—by firms and by authorities. We still lack reliable, granular, and comparable data. That makes it hard to fully assess and manage climate-related risks.

And let’s face it—traditional financial stability tools weren’t built for this. They’re not always fit for purpose when it comes to forward-looking, long-horizon risks like climate change. That’s why developing robust, climate-specific analytical approaches must remain a top priority.

Because climate risk isn’t just an environmental issue. It’s a financial one. And it’s one we can’t afford to ignore.

Let me wrap up.

Financial stability is an international public good. Every single issue I have mentioned today – NBFI, banking, crypto, payments, climate – they all cross borders. And so must our response be.

If we want to meet today’s challenges to financial stability, we have to continue to work together. And we need to stay committed to the international bodies we have built to underpin that cooperation, such as the Basel Committee and the FSB. In a fragmented world, global cooperation is harder. But it is also more essential. During the global financial crisis, policymakers acted swiftly and in unison. We must preserve that capacity.

Because for society, financial stability is like what water is for fish. We barely notice it—until it’s gone. Preserving financial stability is continuous hard work. It is complicated, it is technical, it is not glamorous. Calibrating risk weights for banks doesn’t make headlines. It doesn’t fill the streets with protestors. Therefore, it doesn’t always get the attention it deserves from policy makers, among all the other issues they have on their plate.

But make no mistake: a stable financial system is the foundation for almost all public policy. When financial stability is lost, everything else falls apart. Governments can’t focus on education, or healthcare, or climate. They’re too busy drawing up rescue plans for an economy in free fall.

So we have to continue our work. Which means maintaining our ambition as policy makers to take the agreed policies all the way through to implementation. Let’s keep our eyes on the water. And let’s keep it safe and stable.

FSB appoints Randal K. Quarles to lead G20 strategic review of implementation monitoring

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Ref: 10/2025

  • The Financial Stability Board (FSB) has appointed Randal K. Quarles to chair a high-level group tasked by the G20 with conducting a strategic review of the FSB’s implementation monitoring work.
  • With key reforms developed or nearing completion, the appointment reflects the FSB’s greater focus on promoting and monitoring implementation.
  • The group will assess 15 years of reform implementation, evaluate the effectiveness of the FSB’s tools and processes, and provide recommendations for improvement.

The Financial Stability Board (FSB) has appointed Randal K. Quarles, former FSB Chair and former Vice Chairman for Supervision of the US Federal Reserve Board, to lead a high-level group established at the request of the South African G20 Presidency to review how the FSB monitors implementation of the G20 reforms.

Monitoring the implementation of the G20 financial reforms is a core responsibility in the FSB’s charter. With key reforms developed or nearing completion, the FSB is placing greater focus on promoting and monitoring implementation. The strategic review will assess the effectiveness of the monitoring of post-global financial crisis regulatory reforms and identify areas where the FSB can make improvements in the tools it uses to encourage the consistent, global implementation of agreed reforms.

“Developing policies is not enough. A stable global financial system also requires consistent policy implementation,” said FSB Chair Klaas Knot. “With his exceptional experience in the financial sector and deep understanding of international policymaking, Randy is uniquely qualified to lead this strategic review.”

“I am honoured to assume the role of Chair for this important group,” said Randal Quarles. “At a time when thoughtful international regulatory engagement is essential, I look forward to leading a balanced and independent review—one that advances practical reforms and encourages their collegial and effective implementation.”

The group will deliver an interim report to the G20 in October, which will include a review of the history of reform implementation. Its final report, expected in 2026, will assess the FSB’s implementation monitoring tools and processes to date and provide any recommendations to fulfil the G20’s request.

Notes to editors

Randal Quarles is Chairman and founder of The Cynosure Group, an alternative asset and wealth advisory firm. From October of 2017 through October 2021, Mr. Quarles was Vice Chairman of the Federal Reserve System, serving as the system’s first Vice Chairman for Supervision, charged with ensuring stability of the financial sector. From December 2018 until December 2021, he also served as the Chairman of the Financial Stability Board. He was a key architect of the Fed’s crisis response in March of 2020, credited with maintaining the function of the US and global financial systems, as described in the books Limitless and Trillion Dollar Triage. Earlier in his career, Mr. Quarles was a long-time partner at The Carlyle Group, a leading global private equity firm, and before that a partner at the international law firm of Davis Polk & Wardwell, where he was co-head of their financial services practice. Mr. Quarles has been a close advisor to every Republican Treasury Secretary for the last 35 years, including as Under Secretary of the Treasury in the Bush ’43 Administration. He has represented the United States in meetings of the Group of Seven, Group of Twenty, and Financial Stability Forum, and was also US Executive Director of the IMF.

As part of its mandate, the FSB coordinates and oversees the monitoring of the implementation of agreed financial reforms and its reporting to the G20. This includes reporting on members’ commitments and progress in implementing international financial standards and other policy initiatives; conducting peer reviews of FSB members (which are an obligation of membership); and encouraging global adherence to prudential regulatory and supervisory standards.

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Klaas Knot, President of De Nederlandsche Bank. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.