On February 25, 2025, the IIF submitted a response to the Leverage in Non-Bank Financial Intermediation (NBFI): Consultation report published by the Financial Stability Board (FSB). The IIF response highlighted the need for:

• Publishing a study of the proposed measures in the consultation report prior to advancing policy measures and related recommendations.
• Addressing data challenges and removing obstacles to information sharing.
• Conducting a cost/benefit analysis.
• Targeted and proportionate NBFI policy measures should be applied to the source of vulnerabilities or risks.
• Flexible measures that recognize jurisdictional specificities while recognizing the risks of regulatory fragmentation.
• Differentiating between regulated and non-regulated NBFIs, taking into account the degree to which certain NBFIs commonly engage in highly leveraged strategies.