Henry M. Fields

Henry M. Fields

Morrison & Foerster LLP

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Volcker Rule: Federal Agencies Issue New Guidance Regarding the Seeding Period Treatment for Registered Investment Companies...

Under guidance issued on July 16, 2015 by the federal agencies responsible for implementing the Volcker Rule (the “Agencies”) RICs and FPFs need not be treated as banking entities during a seeding period of up to three...more

7/22/2015 - Business Development Companies Covered Banking Entity Federal Reserve Final Rules Issuers RICs SEC Seed Financing Volcker Rule

Agencies Issue Guidance for Foreign Banking Entities on the Application of the Marketing Restriction for the Volcker Rule’s SOTUS...

On Friday, February 27, 2015, the Volcker Inter-Agency Group posted a new frequently asked question (FAQ 13), clarifying the scope of the so-called “marketing restriction” under the SOTUS covered fund exemption. The SOTUS...more

3/3/2015 - Covered Funds Exemptions Foreign Banks Marketing Trade Restrictions Volcker Rule

Federal Reserve Issues Guidance on Implementation Plans and Other Enhanced Prudential Standards for Foreign Banking Organizations

On June 26, 2014, the Federal Reserve Board (“Board”) published on its website responses to frequently asked questions (“FAQs”) relating to enhanced prudential standards under Section 165 of the Dodd-Frank Act and its...more

7/1/2014 - Dodd-Frank FBOs Federal Reserve Regulation YY

Proposed Narrowing of Licensing Exemption under California Finance Lenders Law

The California Department of Business Oversight (“CDBO”) has proposed to narrow a long-standing interpretation of a statutory licensing exemption for certain lenders under the California Finance Lenders Law (“CFLL”)1. The...more

4/4/2014 - Bank Holding Company Banks Department of Business Oversight Exemptions Lenders Nonbank Firms

Summary of Final Rule Imposing Enhanced Prudential Standards on FBOs

Last week, the Federal Reserve Board (the “Board”) issued its long-awaited final enhanced prudential rule (Regulation YY) under Section 165 of the Dodd-Frank Act (the “Final Rule”) for bank holding companies and foreign...more

2/25/2014 - Banks Dodd-Frank FBOs Federal Reserve Foreign Banks Prudential Standards Regulation YY

The Volcker Rule and Capital Markets Offerings

Final regulations under the section of the Dodd-Frank Act known as the “Volcker Rule” were enacted in December 2013 (the “Final Rule”) by five federal financial regulatory agencies (collectively, the “Agencies”). The Volcker...more

12/31/2013 - Banking Reform Bill Covered Banking Entity Dodd-Frank FBOs Market Making Proprietary Trading Risk Mitigation Underwriting Volcker Rule

The Volcker Rule: Impact of the Final Rule on Foreign Banking Organizations

On December 10, 2013, the Federal Reserve, FDIC, OCC, SEC, and CFTC (the “Agencies”) issued the long-awaited final rule (“Final Rule”) construing the Volcker Rule. The Volcker Rule generally prohibits banking entities — a...more

12/12/2013 - CFTC Exemptions Extraterritoriality Rules FDIC Federal Reserve Foreign Banks OCC Proprietary Trading SEC Sovereign Debt Volcker Rule

Dodd-Frank Implementation: Navigating the Road Ahead

Table of Contents: Introduction; Financial Stability Reform; Resolution Planning; Agencies and Agency Oversight Reform; Securitization Reform; Derivatives Regulation; Investor Protection Reform; Credit Rating Agency...more

12/29/2012 - Capital Requirements CFPB Corporate Governance Credit Ratings Derivatives Disclosure Requirements Dodd-Frank Financial Stability Acts Foreign Banks Mortgage Loan Originators Mortgages Securitization Servicing Policies Volcker Rule

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