The Dodd-Frank Act creates the Financial Stability Oversight Council (FSOC). One of the primary responsibilities of the FSOC is to designate non-banks as “systemically important” and hence requiring of additional oversight by the Federal Reserve. Setting aside the Fed’s at best mixed record on prudential regulation, the intention is that additional scrutiny will minimize any adverse impacts on the economy from the failure of a large non-bank. The requirements and procedures of FSOC have been relatively vague. We have, however, gained some insight into the process since MetLife has chosen to contest FSOC’s designation of MetLife as systemically important.