When the G20 picked up the problem of "systemically important financial institutions" or "SIFIs", the original emphasis was on the question of the "too big to fail" problem arising when the failure of a SIFI leaves public authorities with no option but to bail it out using public funds to avoid financial instability and economic damage. Whilst the issue is relatively clear regarding, for example, banks, the issues are less clear in relation to asset managers and investment funds.
Unfortunately there still seems to be two potential strands of thought: the US FSOC approach running on a distinct track from the international initiatives led by the Financial Stability Board (FSB). It will be interesting to see if these two strands start to converge. Certainly, since the initial papers in 2013, we have helpfully moved from considering the pure size issue into a slightly more sophisticated debate.