Robert H. Ledig

Robert H. Ledig

Dechert LLP

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US Comptroller of the Currency Will Offer Limited Purpose National Bank Charters to Fintech Companies

The Comptroller of the Currency, Thomas Curry, announced on December 2, 2016, that the Office of the Comptroller of the Currency (OCC) intends to move forward with issuing limited purpose national bank charters to financial...more

12/8/2016 - Banks Comptroller FDIC Fintech Charter Innovation National Bank Act OCC Regulatory Burden

The New Future of US Banking and Financial Services Regulation

The presidential election has opened the possibility of significant changes to the Dodd-Frank Act regime that has been implemented over the last six years. It remains to be seen what plans the incoming administration will...more

11/30/2016 - Banks CFPB Dodd-Frank Donald Trump FDIC Financial Institutions FSOC Glass-Steagall Act Liquidation Presidential Elections Shadow Banking Too Big to Fail Trump Administration Volcker Rule

Court of Appeals Says CFPB Is Unconstitutional; Rejects Agency Effort to Apply New Interpretation of Law Retroactively

The courts are now reacting to what some view as regulatory overreach flowing from U.S. laws enacted in the wake of the financial crisis. The most recent example is the October 11, 2016 decision of the U.S. Court of Appeals...more

10/15/2016 - Anti-Kickback Statute Appeals CFPB Constitutional Challenges Director Removal Dodd-Frank Due Process Government Agencies Mortgage Lenders PHH Corp. v CFPB Removal At-Will Removal For-Cause RESPA Reversal Separation of Powers Single Director Statutory Interpretation

Implications of the 2016 Election for Banks, Systemically Important Financial Institutions and Their Investors

Campaign promises rarely turn into specific actions, but when they do, they are necessarily impacted by the dynamics of the legislative process. History suggests, however, that the policies of candidates can be a predictor of...more

10/12/2016 - Acquisitions Banks CFPB Dodd-Frank Donald Trump FDIC Federal Reserve Financial Regulatory Reform Financial Sector FSOC Hillary Clinton Industry Consolidation Liquidity Mergers Mortgages OCC Policy Terms Presidential Elections Receivership SIFIs Too Big to Fail Volcker Rule

CFPB Outlines New Proposals For Third Party Consumer Debt Collection

The Consumer Financial Protection Bureau (CFPB) in the U.S. published an outline of proposals on July 28, 2016 to govern consumer debt collection by debt collectors including third-party collection agencies, debt buyers,...more

9/2/2016 - Burden of Proof CFPB Debt Buyers Debt Collection Debt Collectors Dispute Resolution Dodd-Frank Evidence FDCPA Loan Servicing Mortgage Loan Servicing Standards Native Language Proposed Rules Statute of Limitations Third-Party Service Provider Time-Barred Debt

US Federal Reserve Board Begins the Process of Regulating Insurance Companies

Nearly six years after the adoption of Dodd-Frank’s Title I, which provides for the regulation by the Board of Governors of the Federal Reserve System (Board) of non-bank financial companies – such as insurance companies,...more

7/27/2016 - Advanced Notice of Proposed Rulemaking (ANPRM) Capital Requirements Corporate Governance Dodd-Frank Federal Reserve FRB FSOC Insurance Companies Liquidity Public Comment Risk Management SIFIs SIICs

FSB Issues Proposed Activities-Based Financial Stability Recommendations for the Global Asset Management Industry

The Financial Stability Board (FSB), an international body established by the G-20 in response to the 2008 financial crisis, on June 22, 2016 released its third Consultative Document relating to the regulation and oversight...more

7/8/2016 - Asset Management Comment Period Financial Crisis FSB G-SIFI Global Market Proposed Regulation

Financial Stability Board Issues Proposed Recommendations to Address Perceived Structural Vulnerabilities in the Asset Management...

The Financial Stability Board (FSB), which was established by the G-20 in response to the 2008 financial crisis, on June 22, 2016 issued proposed specific recommendations to address certain perceived threats that the asset...more

6/24/2016 - Asset Management Comment Period Financial Crisis FSB Proposed Regulation

Proposed U.S. Federal Reserve Board Rule’s Impact on Buy-Side Remedies in QFCs with Global Systemically Important Banking...

The Board of Governors of the U.S. Federal Reserve System (Board) recently proposed a rule (Proposed Rule) that will impact parties to any “qualified financial contract” (QFC), as described below, with a global systemically...more

6/16/2016 - FDIC Federal Reserve G-SIB Proposed Regulation Qualified Financial Contracts (QFC)

MetLife Opinion Turns the Tables on FSOC: Back to the Drawing Board

U.S. District Court Judge Rosemary Collyer recently released her opinion invalidating the decision of the Financial Stability Oversight Council (FSOC or the Council) to designate MetLife a systemically important financial...more

4/19/2016 - Administrative Procedure Act Arbitrary and Capricious FSOC Liquidation MetLife Risk Management SIFIs

SEC and FDIC Propose Dodd-Frank Broker-Dealer Resolution Rules

Troubled financial institutions, some with substantial broker dealer operations, played a prominent role in the 2008 financial crisis. In an effort to protect the financial system from serious threats posed by significant...more

4/9/2016 - Broker-Dealer Dodd-Frank FDIC Financial Services Industry Liquidation Receivership SEC SIPC

U.S. District Court Overturns FSOC Designation of MetLife as a Systemically Important Financial Institution

On March 29, 2016, MetLife scored a victory as Judge Rosemary Collyer of the U.S. District Court for the District of Columbia invalidated the Financial Stability Oversight Council’s (FSOC) designation of MetLife as a...more

4/1/2016 - Administrative Authority Arbitrary and Capricious FSOC MetLife SIFIs

U.S. Federal Housing Finance Agency Acts to Prohibit Federal Home Loan Bank Membership by Captive Insurance Companies

The Federal Housing Finance Agency (FHFA or Agency) on January 12, 2016 finalized a portion of the proposed rule that it had issued on September 12, 2014 redrawing the criteria for Federal Home Loan Bank (FHLBank) membership....more

1/16/2016 - Captive Insurance Company Federal Loans FHFA FHLB Mortgage Lenders

Opportunities for Banking Entities Under the Joint Venture Provision of the Volcker Regulations

Under the Volcker Regulations (Regulations), banking entities are sharply restricted in their ability to invest in and sponsor entities that are treated as “covered funds.” During the rulemaking process, the Volcker Agencies...more

10/16/2015 - Banks Covered Funds Joint Venture Volcker Rule

Asset Management Industry: Financial Stability Update, Fall 2015

As U.S. and global regulators continue to evaluate the potential impact, if any, of the asset management industry and its products and activities on financial stability, the regulatory standards that will ultimately be...more

10/6/2015 - Asset Management Financial Stability Acts FSB FSOC Global Economy IOSCO MMF OFR Regulatory Standards SEC SIFIs

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 Institutions 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

3/5/2015

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

2/13/2015

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

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