Jeffrey Werthan

Jeffrey Werthan

Katten Muchin Rosenman LLP

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FDIC Issues Private Letter to Elaborate on Brokered Deposit FAQ

On February 4, representatives of the Federal Deposit Insurance Corporation (FDIC) sent a letter to David Hanrahan, the president and CEO of Capital Bank of New Jersey, in which they elaborated on a particular question and...more

2/19/2015 - Banks Brokered Deposits FDIC Private Letter Rulings

Corporate and Financial Weekly Digest - Volume X, Issue 6

In this issue: - SEC Publishes Rules for Reporting Security-Based Swaps - SEC Proposes Rules for Disclosure of Companies’ Hedging Policies - CFTC Extends Relief From Certain OCR Requirements - NFA...more

2/17/2015 - Arbitration Banking Sector Banks Bribery Brokered Deposits Capital Requirements CFTC Clawbacks FDIC Haiti Hedging NFA OCC SEC Security-Based Swaps Subordination

Regulators Release Guidance on Private Student Loans With Graduated Repayment Terms at Origination

On January 29, the federal financial regulatory agencies, in partnership with the State Liaison Committee of the Federal Financial Institutions Examination Council, issued guidance for financial institutions on private...more

2/12/2015 - CFPB Consumer Lenders ECOA EFTA FDIC New Guidance Private Student Loans Student Loans TILA

Agencies Release Annual CRA Asset-Size Threshold Adjustments for Small and Intermediate

On December 19, 2014, the federal bank regulatory agencies announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank and intermediate small...more

1/16/2015 - Banking Sector Banks CRA FDIC Threshhold Requirements

FDIC Releases Guidance on Brokered Deposits in the Form of FAQs

On January 5, in its second Financial Institution Letter of 2015, the Federal Deposit Insurance Corporation (FDIC) released guidance in the form of frequently asked questions (FAQs) with respect to identifying, accepting and...more

1/16/2015 - Banking Sector Banks Brokered Deposits FDIC New Guidance

FFIEC Releases Revised BSA/AML Examination Manual

On November 26, the Federal Financial Institutions Examination Council (FFIEC) released the revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. ...more

12/12/2014 - Annunzio-Wylie Anti-Money Laundering Act Bank Secrecy Act FDIC Federal Reserve FFIEC Financial Institutions FinCEN Nonbank Firms OFAC

Agencies Request Comment on Proposed Flood Insurance Rule

Five federal regulatory agencies on October 24 announced the approval of a joint notice of proposed rulemaking to amend regulations pertaining to loans secured by property located in special flood hazard areas. The proposed...more

11/5/2014 - Biggert-Waters Flood Insurance Reform Act Farm Credit Administration FDIC Federal Reserve Flood Insurance Flood Zones HFIAA NCUA OCC Proposed Amendments Rulemaking Process

Six Federal Agencies Jointly Approve Final Risk Retention Rule

Six federal agencies approved on October 22 a final rule requiring sponsors of securitization transactions to retain risk in those transactions. The final rule implements the risk retention requirements in the Dodd-Frank Wall...more

11/5/2014 - ABS Asset-Backed Securities Dodd-Frank FDIC Federal Reserve FHFA Final Rules HUD Mortgage-Backed Securities OCC Qualified Mortgage Rule Risk Retention SEC

Banking Agencies Request Comment on Proposed Questions and Answers Regarding Community Reinvestment

On September 8, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency requested comment on proposed revisions to the “Interagency...more

9/18/2014 - Banks Community Reinvestment Act FDIC Federal Reserve OCC Proposed Amendments

Federal Banking Regulators Finalize Liquidity Coverage Ratio

On September 3, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency finalized a rule to strengthen the liquidity positions of large financial institutions.The...more

9/10/2014 - Banks Basel Committee Dodd-Frank FDIC Federal Reserve Final Rules HQLA Liquidity Coverage Ratio OCC

Banking Agencies Adopt Supplementary Leverage Ratio Final Rule

On September 3, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency adopted a final rule modifying the definition of the denominator of the supplementary...more

9/10/2014 - Banks Basel Committee Basel III FDIC Federal Reserve Leverage Ratio OCC

FDIC Proposes Changes to Assessments Rule

On July 15, the Federal Deposit Insurance Corporation (FDIC) proposed (1) to revise the ratios and ratio thresholds for capital evaluations used in its risk-based deposit insurance assessment system (the FDIC stated this was...more

7/24/2014 - Banks Basel III Capital Requirements FDIC Federal Reserve Leverage Capital Ratio OCC

Corporate and Financial Weekly Digest - Volume IX, Issue 28

In this issue: - FINRA Proposes to Adopt Rules on Quotation Requirements for OTC Equity Securities - CFTC Seeks Comment on ICE Clear Europe Portfolio Margining Proposal - New York DFS Proposes First...more

7/21/2014 - CFTC Equity Securities EU FDIC FINRA Margin Requirements Material Misstatements OTC Statute of Repose TCPA Vicarious Liability Virtual Currency

FDIC Releases Resource Guide to Help Institutions Evaluate Opportunities with Community Development Financial Institutions

The Federal Deposit Insurance Corporation (FDIC) has produced a resource guide, Strategies for Community Banks to Develop Partnerships with Community Development Financial Institutions, to inform institutions of strategies to...more

5/14/2014 - Banks CDFI Fund CRA FDIC Public-Private Partnerships

Corporate and Financial Weekly Digest - Volume IX, Issue 19

In this issue: - FINRA Proposes to Amend Rule 11892 - SEC Approves FINRA Rule Change to Limit Self-Trading - FATCA Transitional Relief and Extension of Time for the Implementation of New Account...more

5/12/2014 - Bitcoins Conspiracies Cybersecurity Disclosure Requirements FATCA FCPB FDIC FEC FFIEC FINRA International Tax Issues Investors Privacy Laws Reverse Mergers SEC Self-Dealing

Banking Agencies Adopt Enhanced Supplementary Leverage Ratio Final Rule

On April 8, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) adopted a final rule to strengthen the leverage ratio...more

4/17/2014 - Banks FDIC Federal Reserve Leverage Ratio OCC

Agencies Issue Interim Final TruPs CDOs Rule, Effective April 1

On January 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission and the...more

4/10/2014 - Collateralized Debt Obligations Dodd-Frank FDIC Federal Reserve Trust Preferred Securities Volcker Rule

Corporate and Financial Weekly Digest - Volume IX, Issue 3

In this issue: - CFTC Issues No-Action Relief to FCMs Relating to Enhanced Customer Protection Rules - Eleventh Circuit Upholds Directors’ Affirmative Defenses Based on FDIC’s Post-Receivership Conduct -...more

1/20/2014 - Affirmative Defenses Banks CFTC Collateralized Debt Obligations Directors FCMs FDIC Insider Trading No-Action Relief OCC Professional Liability Receivership Scienter Trust Preferred Securities

Agencies Issue Proposed Guidance on Tax Allocation Agreements Between Insured institutions and Their Holding Companies

On December 19, banking agencies including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (collectively, the agencies)...more

12/26/2013 - Bank Holding Company Commercial Bankruptcy Corporate Taxes FDIC Income Taxes Tax Refunds

Three Financial Regulators Set Volcker Rule Meeting Date

On December 3, three of the five regulators charged with writing the Volcker Rule released notices that they will hold votes on the rule. The U.S. Commodity Futures Trading Commission, the Board of Governors of the Federal...more

12/6/2013 - CFTC FDIC Federal Reserve Volcker Rule

OCC and FDIC Issue Guidance on Deposit Advance Loans

On November 21, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) issued final supervisory “guidance” to supervised financial institutions that offer or may consider...more

11/27/2013 - Compliance Deposit Advances FDIC Loans OCC

OCC and FDIC Propose Rule to Strengthen Liquidity Risk Management

On October 30, as expected, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) each proposed a rule to strengthen the liquidity risk management of large banks and savings...more

11/7/2013 - Banks FDIC Federal Reserve Liquidity Coverage Ratio OCC

Agencies Issue Guidance on Troubled Debt Restructurings

The four federal financial institution regulatory agencies—the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Office of the...more

11/4/2013 - Debt Debt Restructuring FDIC Federal Reserve NCUA Restructuring

Federal Reserve Issues Proposed Liquidity Requirements; OCC and FDIC Expected to Follow

On October 24, the Board of Governors of the Federal Reserve System, in an expected move, issued tough new liquidity requirements generally applicable to banks with assets over $250 billion and somewhat diluted liquidity...more

11/4/2013 - Banks FDIC Federal Reserve Liquidity Coverage Ratio OCC

Federal Reserve and OCC Issue Final Rules Replacing Existing Risk-Based and Leverage Capital Rules

The Office of the Comptroller of the Currency (OCC) and the Board of Governors of the Federal Reserve System published a final rule in the Federal Register on October 11 that replaces their existing risk-based and leverage...more

10/23/2013 - Basel III Capital Requirements Due Diligence FDIC Federal Reserve OCC

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