Oliver I. Ireland

Oliver I. Ireland

Morrison & Foerster LLP

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Latest Publications


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 Companies 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


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

CFPB Increases Penalty Fee Safe Harbor Amounts for Card Issuers

In yesterday’s Federal Register, the Consumer Financial Protection Bureau (“CFPB”) published an amendment to the safe harbor thresholds for credit card penalty fees found in Section 1026.52(b)(1)(ii) of Regulation Z to...more

12/18/2013 - CFPB Consumer Price Index Regulation Z Safe Harbors

A Regulatory Reform Glossary

After the financial crisis, have you ever asked, “What does it all mean?” Now, we have an answer for you: MoFo’s Regulatory Reform Glossary. Since the great financial crisis, financial institutions have been...more

12/17/2013 - Basel III Dodd-Frank EMIR Financial Regulatory Reform MiFID Volcker Rule

The Volcker Rule: Impact of the Final Rule on Foreign Banking Organizations

On December 10, 2013, the Federal Reserve, FDIC, OCC, SEC, and CFTC (the “Agencies”) issued the long-awaited final rule (“Final Rule”) construing the Volcker Rule. The Volcker Rule generally prohibits banking entities — a...more

12/12/2013 - CFTC Exemptions Extraterritoriality Rules FDIC Federal Reserve Foreign Banks OCC Proprietary Trading SEC Sovereign Debt Volcker Rule

CFPB Brings First Enforcement Action Involving Deferred Interest Products, Imposes Novel and Burdensome Application Requirements...

Yesterday, the Consumer Financial Protection Bureau (“CFPB”) announced a consent order with GE Capital Retail Bank and its subsidiary CareCredit (collectively “CareCredit”) related to what the CFPB alleges were unfair and...more

12/12/2013 - Applications CARD Act CFPB Consent Order Credit Cards Deferred Interest Products Disclosure Requirements Enforcement Actions GE Capital Retail Bank Remediation

High Quality Liquid Assets

This is not about top-shelf liquor, it is about today’s notice of proposed rulemaking…. At an open meeting today, the Federal Reserve Board (“FRB”) approved a proposed rule implementing a liquidity coverage ratio (“LCR”)...more

10/25/2013 - Banks Basel III FDIC Federal Reserve Liquidity Coverage Ratio OCC

OFR Report: Asset Managers Potentially Threaten Financial Stability

Asset managers create vulnerabilities “that could pose, amplify, or transmit threats to financial stability,” according to the Treasury Department’s Office of Financial Research (OFR) in a September 2013 report....more

10/4/2013 - Asset Management FSOC Office of Financial Research U.S. Treasury

CFPB Signals Additional Concerns about Consumer Credit Card Market with Report on CARD Act

Yesterday, the Consumer Financial Protection Bureau (“CFPB”) released the “CARD Act Report,” a report summarizing the CFPB’s views on the impact of the Credit Card Accountability Responsibility and Disclosure Act of 2009...more

10/3/2013 - CARD Act CFPB Credit Cards Disclosure Requirements Fees

NY Fed to Establish an Overnight Fixed-Rate Reverse Repo Facility Available to Money Market Funds and Others

The New York Fed quietly announced it is testing a “new tool” that would provide a lifeline for yield-starved money market funds. In a speech today at Fordham University, William C. Dudley, president and chief...more

9/24/2013 - Federal Reserve Money Market Funds Repurchases

D.C. District Court Finds Fed Interchange Rules Are Invalid

On July 31, 2013, the U.S. District Court for the District of Columbia (“District Court”) issued a sharply worded Memorandum Opinion in the merchant litigation with the Federal Reserve Board (“Board”) regarding the Board’s...more

8/5/2013 - Banks Debit and Credit Card Transactions Dodd-Frank Durbin Amendment Rules Federal Reserve Interchange Fees SEC

They’re Here: The Final Interagency Regulatory Capital Rules

The Federal Reserve Board today approved the publication of the long-awaited final regulatory capital rules (“Final Rules” ), which were proposed one year ago (the “Proposed Rules”). While today’s action was taken by the...more

7/5/2013 - Bank Holding Company Basel Committee Basel III Capital Requirements FDIC Federal Reserve Leveraged Lending OCC Risk Management

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