Robert H. Ledig

Robert H. Ledig

Dechert LLP

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US Treasury Eyes Online Marketplace Lending

In an interesting and unusual development, the Treasury Department has issued a notice seeking public input on the online marketplace lending business for small businesses and consumers (“Notice”), setting forth 14 questions...more

8/25/2015 - Non-Bank Lenders Notice and Comment Online Marketplace Lending Preemption Risk Retention U.S. Treasury Usury

Volcker Rule – Five Years On

After years of delays, changes and significant debate, the Volcker Rule is now, largely, in full effect. Sold to a sometimes intellectually incurious Congress and the electorate as a central piece of legislation to limit...more

8/6/2015 - Banking Sector Financial Institutions Hedge Funds Private Equity Funds Proprietary Trading Securitization Special Purpose Vehicles Volcker Rule

Volcker Agencies Provide Guidance Regarding Treatment of Registered Funds and Foreign Public Funds During Their Seeding Period

As the general July 21, 2015 deadline approached to conform with the implementing regulations (Final Rules) for the Volcker Rule, a key issue remained with respect to the sponsoring, organizing and seeding of investment...more

7/29/2015 - Banks Covered Funds Final Rules Financial Institutions Foreign Investment Investment Companies Investment Company Act of 1940 Proprietary Trading Public Funds Registered Funds Volcker Rule

Financial Services Quarterly Report - Second Quarter 2015: U.S. FSOC and Global FSB Signal Continued Scrutiny of Financial...

In recent months, both the U.S. Financial Stability Oversight Council (FSOC or Council) and the international Financial Stability Board (FSB) have taken actions signaling their continued interest in evaluating the potential...more

7/15/2015 - Asset Management Financial Services Industry Financial Stability Acts FSB FSOC G-SIFI Investment Fund Vehicles Investment Funds IOSCO Leverage Ratio Liquidity OFR SIFIs

BNA INSIGHTS: Enforcement Actions Decline But Fines Hit Historic Highs in 2014

During 2014, the number of enforcement actions brought by federal banking agencies1 continued a downward trend that began in 2011. Federal banking agencies issued 661 formal enforcement actions, representing more than a 55...more

6/24/2015 - Banking Sector CFPB Choke Point Civil Monetary Penalty Corporate Fines DOJ Enforcement Actions Enforcement Statistics FDIC Financial Institutions FIRREA Foreign Currency Mortgage-Backed Securities RMBS Strategic Enforcement Plan

U.S. FSOC Proposes Qualified Financial Contract Rules and Creates a New Challenge for Large Financial Companies that are not SIFIs

The Financial Stability Oversight Council (Council) proposed regulations (Rule) on January 7, 2015, which create a new challenge for all nonbank financial companies with assets of $50 billion or more. While the four companies...more

3/26/2015 - Bank Holding Company Dodd-Frank Financing FSOC Nonbank Firms SIFIs

FSB/IOSCO Issue Second Proposal on G-SIFI Designation Methodology for Investment Funds and Asset Managers

On March 4, 2015, the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO) issued a second Consultation (PDF) addressing the potential designation of investment funds and asset...more


FDIC Resolves Doral Bank in a New Receivership Action

The $5.9 billion Doral Bank (San Juan, Puerto Rico), a wholly owned subsidiary of Doral Financial Corporation (Coral Gables, Florida), was closed by the Office of the Commissioner of Financial Institutions of Puerto Rico, on...more

3/3/2015 - FDIC Puerto Rico Receivership

Financial Stability Oversight Council Adopts Supplemental Procedures Relating to SIFI Determinations

The U.S. Financial Stability Oversight Council (“Council”) has now formally responded to increasing concerns regarding the process by which it considers whether to designate a nonbank financial company as a systemically...more


U.S. Financial Stability Oversight Council Requests Comments on Financial Stability Implications of Asset Management Activities

The Financial Stability Oversight Council (“FSOC”) has taken the next step in its consideration of the asset management industry, by issuing a notice requesting public comment on whether asset management products and...more

12/22/2014 - Asset Management Banks Financial Institutions Financial Markets FSOC Public Comment Risk Assessment

Credit Risk Retention Final Rule: Enforcement and Compliance Considerations

Predicting enforcement of the final rule regarding U.S. risk retention is an uncertain task. This OnPoint is designed to provide guidance on possibilities related to consequences of non-compliance, enforcement approaches by...more

12/16/2014 - Asset-Backed Securities CMBS Collateralized Loan Obligations Dodd-Frank Enforcement Guidance Final Rules Private Right of Action Prudential Regulation Authority Risk Retention

FSOC Criticized by Government Accountability Office, but GAO Report Misses Critical Substantive Improvements; FRB Begins to...

The U.S. Government Accountability Office just issued a report on the Financial Stability Oversight Council's (“FSOC”) systemically important financial institution (“SIFI”) designation process, entitled “Further Actions Could...more

11/26/2014 - Federal Reserve FSOC Nonbank Firms Prudential Regulation Authority Prudential Standards SIFIs

Final Credit Risk Retention Rules Adopted for Asset Backed Securities and Residential Mortgage Backed Securities

The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Department of Housing and Urban Development, Federal Housing Finance Agency, and...more

10/29/2014 - Asset-Backed Securities Compliance Dodd-Frank FDIC Federal Reserve FHFA HUD Mortgage-Backed Securities Mortgages OCC Risk Retention RMBS SEC

The Volcker Rule: Overview and Recent Developments Affecting Banking Entities, Funds and Securitization Vehicles

Following years of incubation, in December 2013, five U.S. regulatory agencies – the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the...more

6/30/2014 - CFTC Comptroller Dodd-Frank FDIC Federal Reserve Final Rules SEC Volcker Rule

BNA's Banking Report: Enforcement 2013: Enforcement Actions Continue Three-Year Decline; DOJ Emerges as Major Player

Overall Trends & Outlook - From an enforcement standpoint, 2013 was another historic year in a number of important ways beyond the sheer number of cases, which were again significant. Federal banking agencies1 issued...more

5/29/2014 - Anti-Money Laundering Bank Secrecy Act Banks CFPB DOJ ECOA Enforcement Enforcement Actions FIRREA Risk Management

U.S. Federal Reserve Board Adopts Enhanced Prudential and Intermediate Holding Company Requirements for Foreign Banking...

The Federal Reserve Board (Board) recently adopted final rules representing the most significant change in U.S. regulation of foreign banking organizations (FBOs) since the International Banking Act of 1978. Perhaps most...more

4/9/2014 - Bank Holding Company Banks Federal Reserve Financial Regulatory Reform Foreign Banks

The Housing Finance Reform and Taxpayer Protection Act of 2014

This article provides a brief summary of the key provisions of a new bi-partisan Senate bill, based on the Housing Finance Reform and Taxpayer Protection Act of 2013, as well as a brief discussion of a new House of...more

4/1/2014 - Housing Finance Reform Housing Market

Volcker Rule Regulations Issued: Understanding the Practical Implications for U.S. and Foreign Banking Entities, Funds and...

The Volcker Rule (“Volcker Rule” or “Rule”) is intended to limit risks to the financial system that Congress believes may be created by (i) proprietary trading operations of insured depository institutions, foreign banking...more

1/22/2014 - Banking Sector Collateralized Debt Obligations Dodd-Frank Financial Regulatory Reform Hedge Funds Proprietary Trading Trust Preferred Securities Volcker Rule

FSB and IOSCO to Consider Standards for Treating Investment Funds and Asset Managers as Global Systemically Important Financial...

The Financial Stability Board (FSB), in consultation with the International Organization of Securities Commissions (IOSCO), issued “Assessment Methodologies for Identifying Non-Bank Non-Insurer Global Systemically Important...more

1/17/2014 - Banking Sector Broker-Dealer Financial Companies FSB Global Economy Hedge Funds Investment Funds IOSCO Nonbank Firms Securities

CLOs Under the Volcker Rule: New Exemptions, New Issues, New Obligations

Under the final version of the Volcker Rule issued this week, issuers and sponsors of new CLO issuances should consider structuring CLOs to conform to the exclusions contained in the rule, and banks and bank affiliates that...more

12/17/2013 - Bank Holding Company Banking Sector Collateralized Loan Obligations Derivatives Dodd-Frank FDIC Federal Reserve Financial Regulatory Reform Hedge Funds Investment Fund Vehicles Investment Funds Leveraged Loans Loans Private Equity Funds Reporting Requirements Secured Loans Volcker Rule

U.S. Office of Financial Research Issues Report on Asset Management and Financial Stability

The Office of Financial Research (“OFR”), an office of the U.S. Department of the Treasury, recently issued a report that may provide a roadmap for future designations by the Financial Stability Oversight Council (“FSOC”) of...more

10/8/2013 - Asset Management FSOC Office of Financial Research Risk Management SEC SIFIs

Impact of Ability-to-Repay and Qualified Mortgage Rules on Residential Mortgage Loan Purchasers, RMBS Participants and Mortgage...

Loan originators, their advisors and service providers are moving rapidly to achieve compliance by January 10, 2014 with the Consumer Financial Protection Bureau’s (“Bureau’s”) new rule, which generally imposes an affirmative...more

10/4/2013 - Ability-to-Repay CFPB Dodd-Frank Investors Mortgages Qualified Mortgage Rule

U.S. Basel III Final Rule and its Impact on the Securitization Framework

The three U.S. federal banking agencies (the “Agencies”) have adopted a final rule (the “Rule”) that implements the Basel III regulatory capital framework and comprehensively revises the regulatory capital requirements for...more

9/13/2013 - Banks Basel III Compliance Dodd-Frank New Regulations NPR Securitization

U.S. Regulators Respond to Public Comments and Restructure Proposed Rule for Credit Risk Retention

One of the important unfinished aspects of the Dodd-Frank Act (“Act”) is the requirement for Federal agencies (“Regulators”) to issue regulations implementing Section 941 of the Act which generally requires that a securitizer...more

9/11/2013 - Asset-Backed Securities Collateralized Loan Obligations Disclosure Requirements Dodd-Frank Investors Mortgage-Backed Securities Qualified Mortgage Rule Risk Retention

U.S. Consumer Financial Protection Bureau Acts to Expand Its Authority Over Nonbank Consumer Financial Services Companies

The Consumer Financial Protection Bureau (“Bureau”), pursuant to its authority to extend its supervision to persons that offer or provide any consumer financial product or service that poses a risk to consumers, has adopted a...more

8/15/2013 - CFPB Compliance Dodd-Frank Final Rules Financial Products Financial Regulatory Reform Nonbank Firms

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