Oliver I. Ireland

Oliver I. Ireland

Morrison & Foerster LLP

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Federal Banking Agencies Issue Recommendations as Part of Their Section 620 Report to Solidify the Safety and Soundness of the...

On September 8, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Office of the Comptroller of the Currency (the “OCC,” and...more

9/12/2016 - Bank Holding Company Act Dodd-Frank FDIC Federal Bank Regulatory Agencies Federal Reserve Financial Holding Company Financial Sector Hedging OCC Prudential Standards Risk Management Savings and Loan Companies Volcker Rule

Novel Reading Of Statute Widens CFPB Jurisdiction

Tucked away in a seemingly innocuous paragraph in a complaint, the Consumer Financial Protection Bureau has asserted an extraordinary and potentially far-reaching expansion of its authority. On June 6, 2016, the CFPB...more

6/28/2016 - ACH Payments Administrative Authority CFPA CFPB Covered Person Dodd-Frank Jurisdiction Payment Processors Unfair or Deceptive Trade Practices

Don’t Drain the River: How US Bank Resolution Reform Will Dry Liquidity

Well-meaning initiatives to end the era of US bailouts have also dried-up market liquidity. That could be almost as dangerous - Banks perform critical functions in our economy, one of which is maturity transformation....more

6/15/2016 - Bailout Banking Sector Banks Capital Requirements Dodd-Frank Financial Institutions Liquidity Coverage Ratio Volcker Rule

The Metaphysics Of Systemic Risk

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

5/16/2016 - Asset Management Dodd-Frank Financial Institutions Financial Stability Acts FSOC Risk Assessment

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

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

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

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

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

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

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

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

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

Dodd-Frank Implementation: Navigating the Road Ahead

Table of Contents: Introduction; Financial Stability Reform; Resolution Planning; Agencies and Agency Oversight Reform; Securitization Reform; Derivatives Regulation; Investor Protection Reform; Credit Rating Agency...more

12/29/2012 - Capital Requirements CFPB Corporate Governance Credit Ratings Derivatives Disclosure Requirements Dodd-Frank Financial Stability Acts Foreign Banks Mortgage Loan Originators Mortgages Securitization Servicing Policies Volcker Rule

Financial Services Report -- Winter 2012

In This Issue: Bureau Report; Operations Report; Beltway Report; Arbitration Report; Mortgage Report; Privacy Report; Preemption Report; and Plastics Report. Excerpt from the Bureau Report: World’s Most...more

12/18/2012 - American Express CFPB Chase Bank Cybersecurity Debt Collection Dodd-Frank FDIC FTC Google Mobile Apps MySpace Project Catalyst Stress Tests Truth in Lending Act (TILA)

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