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OCC Permits National Banks And Federal Savings Associations To Use Independent Node Verification Networks And Stablecoins For...

As part of the Office of the Comptroller of the Currency’s (OCC) declared effort to keep pace with a mounting demand for faster, cheaper, and more efficient payments, and the widespread adoption of new technologies, the...more

FDIC Finalizes Supervisory Regime For Industrial Banks And Their Controlling Shareholders

On December 15, 2020, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule (“Final Rule”) setting forth standards to apply to controlling shareholders of industrial banks that are not subject to consolidated...more

Financial Services Report – Winter 2020

Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...more

Financial Services Report – Fall 2020

We join the nation in mourning the passing of Supreme Court Justice Ruth Bader Ginsburg. Over her 20-year career before appointment to the D.C. circuit court, Justice Ginsburg fought for equal rights in the workplace, among...more

Financial Services Report, Summer 2020

Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, 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

Federal Reserve Updates Key Features Of The Main Street Lending Program

On April 30, 2020, the Board of Governors of the Federal Reserve System (“FRB”) announced an expansion of the Main Street Lending Program (“MSLP”) and clarified certain aspects of the program through publication of a list of...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

NY Governor Cuomo Orders Power To Require Waiver Of Deposit Fees During COVID-19 Emergency

As Congress scrambles to pass a stimulus package to alleviate financial strain due to the COVID-19 pandemic, federal regulators and some states are directing financial institutions to provide immediate relief. So far,...more

Agencies Propose Amendments To Volcker Rule Covered Fund Provisions

On January 30, 2020, five federal agencies (the “Agencies”) proposed 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

Federal Regulators Issue Joint Guidance on Banking Hemp-Related Businesses

According to new guidance released on December 3, 2019, banks are not required to file suspicious activity reports (SARs) on customers solely because they are engaged in the legal growth or cultivation of hemp (“Guidance”)....more

Long Awaited HVCRE Rule Clarifies Capital Treatment of Certain Real Estate Loans

On November 19, 2019, the federal banking agencies issued a final rule (the “Final Rule”) that incorporates a new definition of an “HVCRE exposure” into the U.S. regulatory capital rules. The new definition is substantially...more

Financial Services Report, Fall 2019

We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more

Volcker Rule Relief for Foreign Banking Entities

On August 20, 2019, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) approved a final rule (the “2019 Final Rule”) to amend the rules implementing Section 13 of the Bank...more

Amendments to Volcker Rule Regulations

On August 20, 2019, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) approved a final rule (the “2019 Final Rule”) to amend the rules implementing Section 13 of the...more

Agencies Issue Final Rule Conforming Volcker Rule Regulations to 2018 Regulatory Relief Act

On July 22, 2019, five federal agencies (the “Agencies”) published a final rule (the “Final Rule”), which conforms the regulations implementing the Volcker Rule to statutory modifications provided by Sections 203 and 204 of...more

Federal Banking Agencies Release New NPR Expanding HVCRE Proposed Rule

On July 12, 2019, the federal banking agencies released a notice of proposed rulemaking (July NPR) regarding the capital treatment of certain loans that finance land improvements but do not finance the construction of...more

Federal Reserve Proposes New Control Regulations

On April 23, 2019, the Board of Governors of the Federal Reserve System (“Federal Reserve”) released a proposed rule (“Proposed Rule”) to revise regulations related to the determination of “control” under the Bank Holding...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

Federal Reserve and FDIC Issue Proposed Changes to Resolution Plan Requirements for Foreign and Domestic Banking Organizations

The Federal Reserve and the FDIC published proposed changes to resolution plan (or “living will”) requirements applicable to U.S. and foreign banking organizations. The regulatory changes are necessary because the 2018...more

Agencies Propose Conforming Amendments to Volcker Rule Regulations

On December 18, 2018, five federal agencies (the “Agencies”) released a proposed rule (“Proposed Rule”) to conform the regulations implementing the Volcker Rule to statutory modifications provided by Sections 203 and 204 of...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

Agencies to Conform HVCRE Exposure Definition to New Law

As reported in a prior Client Alert, new federal legislation enacted into law on May 24, 2018 narrows the types of acquisition, development, and construction (ADC) loans that may be subject to a heightened risk weight under...more

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