Thomas P. Vartanian

Thomas P. Vartanian

Dechert LLP

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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 Foreign Public Funds (FPFs) Investment Companies Investment Company Act of 1940 Proprietary Trading Public Funds Registered Funds Volcker Rule

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 QFCs 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 - Doral Bank 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

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

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

Dechert's Letter to the SEC Regarding the "Asset Management and Financial Stability" Report by the Office of Financial Research

Full copy of the comment letter recently submitted by Dechert to the Securities & Exchange Commission regarding the Office of Financial Research’s report on "Asset Management and Financial Stability." Dechert is highly...more

11/1/2013 - Asset Management Office of Financial Research SEC

Dechert Submits Comment Letter to the SEC that is Highly Critical of the Office of Financial Research’s Report on “Asset...

Thomas P. Vartanian, Chair of Dechert’s Financial Institutions practice, responded to the U.S. Securities and Exchange Commission's (SEC) request for comments, on behalf of certain clients, by comprehensively criticizing the...more

11/1/2013 - Asset Management Investment Fund Vehicles Mutual Funds Risk Assessment SEC

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

Disparate Impact Discrimination Remains in the Spotlight: Insurance Industry Trade Groups Challenge HUD’s Disparate Impact Rule

Two insurance industry trade groups, the American Insurance Association and the National Association of Mutual Insurance Companies, recently filed suit against the U.S. Department of Housing and Urban Development (HUD)...more

8/13/2013 - Discrimination Disparate Impact Fair Housing Act HUD McCarran-Ferguson Act SCOTUS

Dechert and American Bankers Association Release Strategic Guide to the Ability-to-Repay/Qualified Mortgage Rules; Dechert Follows...

Below is a link to A Strategic Guide to the ATR/QM Rules (Guide), Dechert LLP’s analysis for the American Bankers Association (ABA) of the Ability-to-Repay (ATR) and Qualified Mortgage (QM) rules adopted by the Consumer...more

7/23/2013 - Ability-to-Repay American Bankers Association Guide Lenders Qualified Mortgage Rule

Residential Mortgage Securitization Update: GSE Reform Bill

Senators Bob Corker (R-TN) and Mark Warner (D-VA) have introduced a bi-partisan bill to reform the U.S. housing finance market. Entitled the “Housing Finance Reform and Taxpayer Protection Act of 2013” (the “Reform Bill” or...more

7/12/2013 - Compliance FHFA FMIC Housing Finance Reform Mortgage Insurance Fund Mortgages RMBS

American Bankers Association Real Estate Lending Conference - Qualified Mortgages: A Sea Change For Mortgage Lenders

In This Presentation: - The Qualified Mortgage (QM) Rule - Small Creditor QM Proposal - The Ability-to-Repay (ATR) Rule: What It Says and What It Means - Liability for Failure to Comply with the ATR and QM...more

4/16/2013 - Ability-to-Repay CFPB Disparate Impact Fair Lending HUD Lenders Loans Mortgages Qualified Mortgage Rule Safe Harbors Underwriting

2012 Bank Enforcement Actions Still High, But Significantly Lower Than 2010-11

Originally published in BNA’s Banking Report, 100 BBR 617 on 04/02/2013. Overall Trends & Outlook - In 2012, the federal banking agencies, including the Federal Deposit Insurance Corporation (‘‘FDIC’’), Office...more

4/4/2013 - Anti-Money Laundering CFPB Enforcement Actions Fair Lending FCRA FDIC FinCEN Mortgage Reform OCC OFAC Unfair or Deceptive Trade Practices

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