Oliver I. Ireland

Oliver I. Ireland

Morrison & Foerster LLP

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Is the End in Sight? FDIC Proposes the Net Stable Funding Ratio (“NSFR”): Liquidity Risk Measurement Standards and Disclosure...

On April 26, 2016, the Federal Deposit Insurance Corporation (the “FDIC”) proposed a rule (the “Proposed Rule”) that would implement a quantitative long-term liquidity requirement—the net stable funding ratio (“NSFR”)—for...more

4/28/2016 - Banking Regulators Banking Sector Derivatives Disclosure Requirements FDIC Liquidity Risk Management Rule Net Stable Funding Ratio (NSFR) Proposed Regulation

Possible Worlds Versus Probable Worlds - the Metaphysics of Systemic Risk: FSOC Revisits Asset Managers

On April 18, 2016, the Financial Stability Oversight Council (FSOC) again warned that asset managers present systemic risk to financial stability in five key areas: ..liquidity and redemptions; ..leverage;...more

4/27/2016 - Asset Management Dodd-Frank FSOC Mutual Funds SEC

New Executive Compensation Rule At-A-Glance

On April 21, 2016, the National Credit Union Administration approved a proposed rule on incentive compensation under Section 956 of the Dodd-Frank Act. The other appropriate Federal regulators, as defined in Section 956, are...more

4/26/2016 - Covered Entities Dodd-Frank ERISA Executive Compensation NCUA

Supreme Court Affirmation of Hawkins Case Raises More Questions Than It Answers

On March 22, 2016, the Supreme Court of the United States issued an order in Hawkins v. Community Bank of Raymore. An evenly divided Court affirmed the Eighth Circuit decision without issuing an opinion, thereby resolving...more

3/28/2016 - Commercial Loans ECOA Family Status Discrimination Guarantors Hawkins v Community Bank of Raymore Reaffirmation Regulation B SCOTUS Split of Authority Spouses

Another Brick in the Wall: The Fed Reproposes Single-Counterparty Credit Limits for Large Banking Organizations

On March 4, 2016, the Board of Governors of the Federal Reserve System (the “Fed”) issued a Notice of Proposed Rulemaking (“NPRM”), inviting comment on reproposed rules (the “Reproposed Rules”) that would establish single...more

3/10/2016 - Bank Holding Company Banks Credit Dodd-Frank Federal Reserve Foreign Banks NPRM

Financial Services Report, Spring 2016

Why another law firm newsletter? Over ten years ago, Will Stern answered that question in the first Editor’s Note of the first Financial Services Report. Some things have changed since then—we no longer print and mail paper...more

3/9/2016 - Arbitration CFPB Credit Cards Customer Lists Cybersecurity Debt Collection DOJ EU-US Privacy Shield Fair Lending FCRA FDIC Federal Reserve FTC HMDA Mortgages OCC Payday Loans Preemption SEC TCPA Truth in Lending Act (TILA)

Too-big-to fail, RIP?

The latest set of prudential rules is the strongest sign yet that too-big-to-fail has seen its last days - Despite the comprehensive reforms put in place in the wake of the financial crisis by the landmark Dodd-Frank...more

2/23/2016 - Bailout Bank Holding Company Dodd-Frank FBOs TLAC Too Big to Fail

Bureau Tells Banks to Offer Overdraft-Free Accounts, Sends Warning on Reporting

On February 3, 2016, the Consumer Financial Protection Bureau (CFPB or “Bureau”) announced a series of steps designed to improve consumer access to checking accounts by (a) encouraging banks and credit unions to make...more

2/4/2016 - Banking Sector CFPB Checking Accounts Consumer Reporting Agencies Deposit Accounts Overdraft Fees

Bubble, Bubble Toil and Trouble: The Fed Breathes Life into the Countercyclical Capital Buffer

Widespread problems in the banking system are often associated with sharp declines in asset prices, or the economy more broadly. When these declines result in loan defaults, bank capital can erode, leading to more stringent...more

12/24/2015 - Banks Basel III Dodd-Frank FDIC Federal Reserve

TLAC, and Then Some… A Preliminary Assessment of the Federal Reserve Board’s NPR

On Friday, October 30, 2015, the Federal Reserve Board (“Board”) reaffirmed its commitment to both the bank holding company model and single point of entry resolution. In a departure from historical views of the purpose and...more

11/2/2015 - Bank Holding Company Banking Sector Comment Period Debt Disclosure Requirements Dodd-Frank FBOs Federal Reserve G-SIB Holding Companies NPRM Proposed Regulation Public Disclosure Receivership Structured Financial Products Subsidiaries Too Big to Fail Unsecured Debt

LCR – The Fed Takes Tentative Step to Expand HQLAs

When the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “Board”) and the Federal Deposit Insurance Corporation (the “FDIC”) finalized the Liquidity Coverage...more

6/2/2015 - Bank Holding Company Banks FDIC Federal Reserve Financial Institutions HQLA Liquidity Coverage Ratio Municipal Securities Issuers OCC

Suspension of Contractual Rights of Counterparties to UK Banks

On 26 May 2015, the Prudential Regulation Authority (“PRA”) of the UK issued a consultation paper entitled “Contractual stays in financial contracts governed by third-country law”, proposing a new restriction that would apply...more

6/2/2015 - Banks EU Financial Institutions Financial Stability Acts Insolvency Investment Firms Prudential Regulation Authority UK

OCC Takes a Page from the CFPB’s Playbook on Overdraft Programs

On February 11, 2015, the Office of the Comptroller of the Currency (“OCC”) issued an “updated” installment to the Comptroller’s Handbook in a new booklet entitled “Deposit-Related Consumer Credit.” In doing so, the OCC stole...more

2/13/2015 - Banks CFPB Financial Institutions Letter of Credit OCC Overdraft Fees

House Passes Bill to Ease Volcker Rule and other Regulatory Requirements

The U.S. House of Representatives on January 14, 2015, voted (271-154) to pass H.R. 37, the “Promoting Job Creation and Reducing Small Business Burdens Act.” If enacted, the bill, among other things, would extend the Volcker...more

1/19/2015 - Collateralized Loan Obligations Investment Adviser JOBS Act Pending Legislation SBIC Venture Capital Volcker Rule

FSOC, At It Again, Places Asset Managers in Its Crosshairs

In seeking comment on potential risks to the U.S. financial system created by asset managers, the Financial Stability Oversight Council (FSOC) again places asset managers in its crosshairs. This crusade potentially can lead...more

1/9/2015 - Asset Management Banking Sector Banks CPOs Financial Institutions FSOC Hedge Funds Insurance Industry Risk Assessment SEC

Finalized Liquidity Coverage Ratio

The Board of Governors of the Federal Reserve System (the “Board”), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) (collectively, the “agencies”) issued the finalized...more

9/5/2014

CFPB Complaints Database Expands to Include Prepaid Cards and Nonbank Products

On July 21, 2014, the Consumer Financial Protection Bureau (“CFPB”) announced that it has further expanded its Consumer Complaint Database (“Database”) to include additional types of financial products. Specifically, the CFPB...more

7/23/2014 - CFPB Consumer Complaint System Credit Repair Services Debt Settlement Services Prepaid Payment Products

Bureau Proposes Sharing Consumer Narratives in Complaints Database

On July 17, 2014, the Consumer Financial Protection Bureau (“CFPB”) held a field hearing in El Paso, Texas to announce a new policy proposal (“Proposal”) that would expand the Consumer Complaint Database (“Database”) to allow...more

7/22/2014 - CFPB Consumer Complaint System

Federal Reserve Issues Guidance on Implementation Plans and Other Enhanced Prudential Standards for Foreign Banking Organizations

On June 26, 2014, the Federal Reserve Board (“Board”) published on its website responses to frequently asked questions (“FAQs”) relating to enhanced prudential standards under Section 165 of the Dodd-Frank Act and its...more

7/1/2014 - Dodd-Frank FBOs Federal Reserve Regulation YY

Housing Finance Reform

Efforts to address housing finance reform are starting to heat up, although the finish line is still probably a long way off. Fannie Mae and Freddie Mac remain in conservatorship, even though they are making money, and the...more

4/29/2014 - Fannie Mae Freddie Mac Housing Finance Reform Mortgages

The Volcker Rule’s Trojan Horse for Smaller Banking Entities

The final rules recently enacted to implement the Volcker Rule (‘‘the Final Rules’’) impose on the largest banking entities a highly detailed and complex compliance regime. As to those so-called ‘‘less active banking...more

4/10/2014 - Banks Collateralized Debt Obligations Compliance Proprietary Trading Trust Preferred Securities Volcker Rule

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

2/25/2014 - Banks Dodd-Frank FBOs Federal Reserve Foreign Banks Prudential Standards Regulation YY

Toke on This: FinCEN Issues Guidelines for Marijuana-Related Businesses

The Financial Crimes Enforcement Network (FinCEN) got a whiff of the fact that financial institutions provide services to burgeoning marijuana-related businesses and published guidance to clarify customer due diligence...more

2/24/2014 - Bank Secrecy Act Controlled Substances Act FinCEN Marijuana Money Laundering

CFPB Proposes Definition of Larger Participants for the International Money Transfer Market

On January 23, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule that would define which nonbank covered persons would be designated “larger participants” for purposes of the international money...more

1/27/2014 - CFPB Debt Collection Dodd-Frank Electronic Fund Transfer Act Larger Participant Money Transfer Nonbank Firms Regulation E Student Loans

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