As previously discussed, a central item in the new regulatory reform bill is the creation of the Financial Stability Oversight Council to oversee systemically significant financial firms. To assist the council, the bill also creates a new office within the Department of the Treasury known as the Office of Financial Research. The primary purpose of the Office of Financial Research will be to collect and analyze data for the council’s use in its functions.

 While the functions of the Office of Financial Research will certainly lead to enhanced reporting requirements for bank holding companies with $50 billion or more in consolidated assets (as well as the added burden of contributing to the funding of the office), it is reasonable to expect that the office will need additional data from the financial industry as a whole in order to provide context in its analysis of data collected from large financial firms. For that reason, the conference text of the regulatory reform bill allows the office, after consultation with its director and the Financial Stability Oversight Council, to require the submission of periodic or other data from any financial company (which would include banks and bank holding companies of any size) in order to assess “the extent to which a financial activity or financial market in which the financial company participates…poses a threat to the financial stability of the United States.”

 The information the Office of Financial Research will deem important in providing analysis to the council and from which financial companies the office will seek the information remain to be seen. Certain provisions of the bill are designed to minimize duplication in reporting, and, as such, one would hope the additional reporting will be limited to modifications of existing reporting forms. It is clear, however, that its reach extends beyond the large firms that could pose systemic risk to the financial industry.