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To Approve a Bank Merger or Not: That Is the Question!

On January 29, 2024, the OCC issued a proposed policy statement[1] describing the general principles it uses to evaluate applications for approval of transactions under the Bank Merger Act (“BMA”), principally bank mergers,...more

FDIC Bank Receivership Frequently Asked Questions - UPDATED 3/20/2023

UPDATE (3/20 PM): Developments Related to Flagstar Bank, SVBB, SVB Financial Group, Credit Suisse, and First Republic Bank- On March 19, 2023, the FDIC announced that the agency has entered into a purchase and...more

Agencies Finalize Amendments To Volcker Rule Covered Fund Provisions

On June 25, 2020, five federal agencies (the “Agencies”) finalized amendments to the rules implementing section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) related to the prohibition on investing,...more

FDIC Opens For Business For Industrial Banks

On March 17, 2020, the Federal Deposit Insurance Corporation (FDIC) announced two significant developments relating to industrial banks (also sometimes called industrial loan companies). First, in a notice of proposed...more

Federal Reserve Board Establishes Stress Capital Buffer For Large Banks

On March 4, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) approved a final rule amending several of the Federal Reserve’s regulations and policies (and making associated changes to...more

Banking Agencies Propose a More Tiered Approach to Large Foreign Bank Supervision

On April 8, 2019, the federal banking agencies (the “Agencies”) released two proposals (the “Tailoring Proposals”) which, if adopted, would further tailor the approach to supervision of large foreign banking organizations...more

Agencies Propose Simplification of Capital Rules for Community Banks

On November 21, 2018, the federal banking agencies (the “Agencies”) released a proposal (the “Proposed Rule”) to simplify the regulatory capital requirements for qualifying community banking organizations (QCBOs) (i.e.,...more

Agencies Propose a More Tiered Approach to Large Bank Supervision

On October 31, 2018, the federal banking agencies released two separate proposals that, if adopted, would create a more consistent tiered approach to large bank supervision – in other words, supervision of banking...more

Federal Reserve Board Revises FR Y-7 and Provides Guidance on Enhanced Prudential Standards for Foreign Banking Organizations

On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more

House Financial Services Committee Holds Hearing on the Financial CHOICE Act of 2017

On April 26, 2017, the Financial Services Committee of the U.S. House of Representatives held a hearing entitled "A Legislative Proposal to Create Hope and Opportunity for Investors, Consumers, and Entrepreneurs." The purpose...more

Agencies Issue Guidance on Capital Deduction Requirement under the Volcker Rule for Investments in Collateralized Debt Obligations...

On Friday, March 4, 2016, the Volcker Inter-Agency Group posted a new frequently asked question (FAQ 21), clarifying the capital deduction requirement under the Volcker Rule for investments in Qualifying TruPS CDOs. FAQ 21...more

Narrowing of Licensing Exemption Under California Finance Lenders Law for Consumer Lenders and Brokers

The California Department of Business Oversight (the “CDBO”) has issued a new regulation that will eliminate a statutory licensing exemption under the California Finance Lenders Law (the “CFLL”) for nonbank operating...more

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

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

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