Keith R. Fisher

Keith R. Fisher

Ballard Spahr LLP

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Despite FAQs and OCC Interim Examination Procedures, Little Illumination So Far for Volcker Rule Compliance

June 2014 saw the publication of some interagency FAQs on the Volcker Rule (the Rule) and interim procedures from the Office of the Comptroller of the Currency (OCC) for its examiners to use in assessing progress by national...more

8/29/2014 - Banking Sector Banks Compliance Enforcement Guidance FDIC Federal Reserve Foreign Banks OCC Volcker Rule

FDIC Issues Guidance on Basel III Capital Conservation Buffer for Subchapter S Banks

A recent Financial Institution Letter provides guidance on the FDIC’s methodology when entertaining requests from banks or savings associations organized as Subchapter S corporations (S-corporation banks) to pay dividends to...more

8/15/2014 - Banks Basel Committee Basel III Capital Controls FDIC S-Corporation

Volcker Rule Promises To Be Godzilla of Bank Regulation

It took almost 3½ years before it finally hatched. And it was big—very big—enormous, in fact. No, it’s not Godzilla. It’s the Volcker Rule. More than two years after the Notice of Proposed Rulemaking, a final rule...more

12/30/2013 - Bank Holding Company Act Banks Dodd-Frank FDIC Federal Reserve OCC Proprietary Trading SEC Volcker Rule

Regulators Revise Interagency Q&A on the Community Reinvestment Act

Recently, the federal banking agencies—the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation—issued revisions to Interagency...more

12/20/2013 - Community Development Entities CRA FDIC Federal Reserve Insured Depository Institutions Lenders OCC

Prudential Regulators Clarify Supervisory Approach Relative to CFPB Mortgage Regulation

The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the National Credit Union Administration, and the Office of the Comptroller of the Currency (the “Prudential Regulators”) have...more

12/20/2013 - Ability-to-Repay CFPB CRA FDIC Federal Reserve Mortgages NCUA OCC Qualified Mortgage Rule

FDIC Clarifies Position on Bank Payment Processing for Payday Lenders and High-Risk Merchants

Last week, the FDIC issued the latest in a series of Financial Institutions Letters dating back to 2008 on the subject of banks managing third-party risk. This most recent FIL deals with payment processing for third-party...more

10/3/2013 - Banks FDIC Payday Loans

Despite Controversy, Implementation of U.S. Basel III Capital Regime Moves Forward

In June 2012, the Board of Governors of the Federal Reserve System (the “Board”), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) issued proposed regulations that...more

7/26/2013 - Banks Basel III Dodd-Frank FDIC OCC Proposed Regulation

Federal Reserve Issues Interim Final Rule on Federal Assistance to Swap Entities

Section 716(a) of the Dodd-Frank legislation forbids "Federal assistance" with respect to swaps, security-based swaps, or other activity of any "swaps entity."...more

7/16/2013 - CFTC FDIC Federal Reserve Major Swap Participants SEC Securities Exchange Act Swap Dealers Swaps

Congress Passes Legislation To Fix CFPB Privilege Waiver Problem

The U.S. Senate, by unanimous consent, has passed a bill (H.R. 4014) that amends the Federal Deposit Insurance Act to provide protection against waiver of the attorney-client privilege when privileged information is shared...more

12/14/2012 - Attorney-Client Privilege CFPB FDIC Waivers

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