Oliver I. Ireland

Oliver I. Ireland

Morrison & Foerster LLP

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Structured Thoughts: News for the financial services community - Special Issue

Final TLAC Rules and Structured Products - On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued its final rules regarding long-term debt and total loss absorbing...more

12/27/2016 - Depository Institutions EU EU Benchmark Regulation Fiduciary Rule FINRA Foreign Banks G-SIB Holding Companies IRS MiFID II Packaged Retail And Insurance-Based Investment Products (PRIIPS) Popular Regulatory Agenda Section 871(m) Structured Financial Products TLAC UK UK Brexit

A Closer Look at the Final TLAC Rule’s Requirements for IHCs

On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued final rules requiring global systemically important banks (“G-SIBs”) in the United States, including bank holding...more

12/23/2016 - Bank Holding Company FDIC Federal Reserve G-SIB TLAC

TLAC’s Back! Sifting Through the Federal Reserve’s Final TLAC Rule

On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued its final rules regarding total loss absorbing capacity (the “Final TLAC Rule”) requirements for global systemically...more

12/17/2016 - Bank Holding Company Capital Requirements Federal Reserve G-SIB Grace Period Grandfathered Status Holding Companies TLAC

Federal Reserve Board Announces Procedures to Request an Extended Transition Period to Conform Illiquid Funds to the Volcker Rule

On December 9, 2016, the Board of Governors of the Federal Reserve System (“Federal Reserve Board”) issued SR 16-18, “Procedures for a Banking Entity to Request an Extended Transition Period for Illiquid Funds” (“SR 1618”). A...more

12/14/2016 - Banking Sector Covered Funds Extensions Federal Reserve Investment Policy Statement Volcker Rule

Shaping MREL for European (and non-European) Banks

The European Commission (“Commission”), on 23 November 2016, released its legislative proposals to amend the EU’s Bank Recovery and Resolution Directive (“BRRD”) to provide more detailed rules relating to the setting of MREL...more

12/12/2016 - Banks Bonds BRRD Capital Requirements Regulation (CRR) EU European Commission Holding Companies Insolvency MREL Structured Financial Products Subordination TLAC

Financial Services Report, Winter 2016

EDITOR’S NOTE - Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more

12/7/2016 - Arbitration Article III Blockchain CalOPPA CFPB Consent Order Consumer Lenders Credit Card Surcharges Cybersecurity Data Breach Distributed Denial of Service ECOA FDCPA Federal Reserve FinTech FTC HMDA HUD LGBT Military Lending Act NYDFS OCC OIG Prepaid Payment Products Risk Management SCRA Spokeo v Robins Truth in Lending Act (TILA)

OCC Announces Special Purpose National Bank Charter for FinTech Companies

On December 2, 2016, Comptroller of the Currency Thomas Curry confirmed that the agency will begin considering applications from FinTech companies to become special purpose national banks, saying that the OCC will charter...more

12/5/2016 - Applications Banking Sector FDIC FinTech OCC Public Comment

When CFPB Finds Deception Regardless Of A Lender’s Intent

There is a tendency to think of consumer fraud and misrepresentation as intentional acts that deceive consumers into engaging in transactions that they would not otherwise engage in. A recent case demonstrates that the...more

9/30/2016 - CFPB Financial Institutions Loans Misrepresentation Summary Judgment UDAAP

The Fed Revisits CCAR and Proposes CCAR Relief for Large Noncomplex Firms

One of the notable financial regulatory tools that resulted from the post-financial crisis prudential regulations is stress testing. The Board of Governors of the Federal Reserve System (the “Federal Reserve”) has the...more

9/29/2016 - CCAR Central Counterparties Consumer Protection Act Dividends Dodd-Frank Federal Reserve Financial Institutions G-SIB Nonbank Firms Reporting Requirements Stress Tests Threshold Requirements Transparency

Financial Services Report, Fall 2016

Editor’s Note - So much for summer! The weather is cooling, the kids are back to school, and we better not see you wearing white so long after Labor Day! For those of you having a little trouble getting back in the...more

9/21/2016 - Anti-Money Laundering Arbitration CFPB Civil Monetary Penalty Debt Collection Digital Currency EU EU-US Privacy Shield Fair Lending FDIC FinCEN Foreclosure FTC Homeowner Bill of Rights Mortgage Lenders Municipalities OCC Online Banking SEC Standing Tax Revenues TCPA Telemarketing Volcker Rule

Structured Thoughts: News for the financial services community, Volume 7, Issue 9

Updating Unregistered Structured Note Programs: How Frequently? - For some types of securities offering programs, we have “black letter law” that instructs issuers how frequently the program documentation should be...more

9/15/2016 - BaFin Bank Holding Company Brokerage Accounts Cease and Desist Orders Duty to Update Federal Reserve Financial Sector FINRA Fixed Income Investments Germany Income Tax Act Private Funds SEC Subsidiaries TLAC TRACE

H.R. 5983—Act as Introduced—Title I

U.S. Congressman Jeb Hensarling, Chairman of the House Financial Services Committee, has set the stage for the consideration of regulatory reform and burden reduction with the introduction of H.R. 5983, the “Financial Choice...more

9/13/2016 - Banking Sector Exemptions Financial Institutions Financial Services Committee Regulatory Reform Title I

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

ACH Debit Transactions – Whose Agent Are You?

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

6/24/2016 - ACH Payments CFPA CFPB Covered Providers Debit and Credit Card Transactions Enforcement Actions Payment Processors Third-Party Service Provider 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

Penny Proof for Deposits: Federal Banking Regulators Issue Interagency Guidance Regarding Deposit Reconciliation Practices

On May 18, 2016, five federal banking agencies—the Board of Governors of the Federal Reserve System (“Board”), the Consumer Financial Protection Bureau (“CFPB”), the Federal Deposit Insurance Corporation (“FDIC”), the...more

5/23/2016 - Banking Regulators CFPB Deposit Accounts Expedited Funds Availability Act (EFAA) FDIC Federal Reserve Financial Institutions OCC

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

Bankers' poll: TLAC and the future of bank debt

To say bank bonds had a rocky start to 2016 would be an understatement. Over the first weeks of January, the market’s significant gains from last year were essentially wiped out, with European issuers hit particularly hard....more

5/3/2016 - Banking Sector Bonds BRRD China Debt Debt Market EU FSB Global Economy Investors Non-Marketable Debt Instruments TLAC

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

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