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Final Federal Reserve Rules for Foreign Banking Organizations

This Alert describes the final regulations issued by the Federal Reserve Board (the “FRB”) on February 18, 2014, that radically modify the former requirements applicable to foreign banking organizations (“FBOs”) pursuant to...more

The Volcker Rule—A Suggested Approach for Banking Entities When Analyzing its Impact on Business Models, Activities and...

More than three years following the passage of the Dodd-Frank Act, and intense inter-agency negotiations, the federal financial regulatory agencies collectively adopted the final version of the “Volcker Rule,” or “Rule”—which...more

CFPB's Arbitration Study—A Warning to Consumer Financial Service Companies

On December 12, 2013, the Consumer Financial Protection Bureau published its “Arbitration Study Preliminary Results,” mandated by Section 1028(a) of the Dodd-Frank Act (the “Study”). Unfortunately (and despite its statements...more

Dealing with Civil Investigative Demands from the CFPB—Rules, Responses & Pitfalls

The Consumer Financial Protection Bureau’s civil investigative demand (“CID”) authority has recently presented significant compliance difficulties for companies that have received requests for information relating to an...more

5/9/2013  /  CFPB , CID , Dodd-Frank , FDIC , FTC

Banks Face New Obligations in Underwriting, Risk Analysis, and Management of Leveraged Lending

This Alert describes the recently issued guidance (the “Guidance”) from the U.S. banking agencies instructing regulated domestic and foreign banks, subsidiaries and affiliates on implementing an acceptable infrastructure to...more

Update on Preparing Living Wills for Bank Holding Companies and Depository Institutions

This analysis updates a previous memo and incorporates advice we have received from the Federal Reserve Board (“FRB”) and the Federal Deposit Insurance Corporation (“FDIC”) regarding the preparation of living wills for bank...more

Trends in Single-Family Housing

Rising home values in many areas of the country and improved economic data have buoyed hopes that the recession may be behind us, but no one expects an immediate return of either pre-2007 home value appreciation or the loose...more

An Update on Preparing Living Wills for Foreign Banking Organizations — Exemptions and Important Strategy Considerations

This analysis updates a previous memo and incorporates advice we have received from the Federal Reserve Board (“FRB”) and the Federal Deposit Insurance Corporation (“FDIC”) regarding the preparation of living wills by covered...more

12/3/2012  /  FBOs , FDIC , Federal Reserve , Living Will
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