Daily Financial Regulation Update -- Saturday, April 22, 2023

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Major Developments

Financial Stability Oversight Council

FSOC Issues for Public Comment Proposed Analytic Framework for Financial Stability Risks and Proposed Guidance on Nonbank Financial Company Determinations

April 21, 2023

The Financial Stability Oversight Council (Council) voted unanimously to issue for public comment a proposed analytic framework for financial stability risks. The Council also voted unanimously to issue for public comment new proposed interpretative guidance on the Council's procedures for designating nonbank financial companies for Board of Governors of the Federal Reserve System (Federal Reserve) supervision and enhanced prudential standards.

Federal Agencies

U.S. Department of the Treasury

Remarks by Assistant Secretary for Terrorist Financing and Financial Crime Elizabeth Rosenberg on DeFi Risk Assessment at the Atlantic Council

April 21, 2023

Assistant Secretary for Terrorist Financing and Financial Crime Elizabeth Rosenberg gave remarks at the Atlantic Council on DeFi risk assessment.

Remarks by Under Secretary Brian Nelson at American Chamber of Commerce Austria Roundtable

April 21, 2023

Under Secretary Brian Nelson gave remarks about Russia's invasion of Ukraine at the American Chamber of Commerce Austria Roundtable.

Federal Reserve Board
Office of the Comptroller of the Currency
Federal Deposit Insurance Corporation
National Credit Union Administration

Revised Interagency Policy Statement on Allowances for Credit Losses

April 21, 2023

The Federal Reserve Board, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, and National Credit Union Administration have jointly issued a revised Interagency Policy Statement on Allowances for Credit Losses.

Federal Reserve Board

Federal Reserve issues initial findings from its 2022 triennial payments study

April 21, 2023

The Federal Reserve on Friday issued initial findings from its 2022 triennial payments study.

Financial Crimes Enforcement Network

FinCEN Renews and Expands Real Estate Geographic Targeting Orders

April 21, 2023

The Financial Crimes Enforcement Network announced the renewal and expansion of its Geographic Targeting Orders that require U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate.

Fannie Mae

Economy Resumes Gradual Slowdown Following Bank Turmoil

April 21, 2023

Fannie Mae's Economic and Strategic Research Group now forecasts stronger first quarter GDP growth but maintains its belief that economic momentum is running out of steam, according to the ESR Group's latest monthly commentary.

Bank Policy Institute

One-Pager: Operational Risk: What It Means and Why It Matters

April 21, 2023

The Bank Policy Institute published a one-pager entitled, "Operational Risk: What It Means and Why It Matters."

International

European Banking Authority

EBA consults on the draft Guidelines on the STS criteria for on-balance-sheet securitisations

April 21, 2023

The European Banking Authority launched a public consultation on its draft Guidelines on the criteria related to simplicity, standardisation and transparency and additional specific criteria for on-balance-sheet securitisations.

EBA updates list of institutions involved in the 2023 supervisory benchmarking exercise

April 21, 2023

The European Banking Authority published an updated list of institutions, which have a reporting obligation for the purpose of the 2023 EU supervisory benchmarking exercise.

Bank of England

Paper: Financial services trade restrictions and lending from an international financial centre

April 21, 2023

The Bank of England published a staff working paper entitled, "Financial services trade restrictions and lending from an international financial centre."

UK Financial Conduct Authority

FCA sets out multi-occupancy leasehold insurance reforms

April 21, 2023

The UK Financial Conduct Authority proposed new rights and protections for leaseholders to improve the transparency of the multi-occupancy leasehold buildings insurance market.

Administration Changes

Vacancies

Board of Governors of the Federal Reserve System

  • Vice Chair – Vacant (Vice Chair Leal Brainard resigned effective on or around February 20, 2023)

Office of the Comptroller of the Currency

  • Comptroller – Vacant (Michael Hsu serves as Acting Comptroller)

Financial Crimes Enforcement Network

  • Director – Vacant (Himamauli Das serves as Acting Director)

Appointments/Confirmation Hearings

U.S. Department of the Treasury – Janet Yellen (effective January 26, 2021)

Federal Reserve Board – Jerome H. Powell (effective May 23, 2022)

Federal Reserve Bank of New York – John C. Williams (effective June 18, 2018)

Federal Reserve Bank of Boston – Susan M. Collins (effective July 1, 2022)

Federal Deposit Insurance Corporation – Martin Gruenberg (effective January 5, 2023)

Office of the Comptroller of the Currency – Michael Hsu (acting Comptroller, effective May 10, 2021)

Securities and Exchange Commission – Gary Gensler (effective April 17, 2021)

Commodity Futures Trading Commission – Rostin Behnam (effective December 17, 2021)

Consumer Financial Protection Bureau – Rohit Chopra (effective October 12, 2021)

National Credit Union Administration – Todd M. Harper (effective January 20, 2021)

Small Business Administration – Isabella Casillas Guzman (effective March 16, 2021)

U.S. Department of Housing and Urban Development – Marcia Fudge (effective March 10, 2021)

Federal Housing Finance Agency – Sandra L. Thompson (effective June 22, 2022)

U.S. Department of Education – Dr. Miguel Cardona (effective March 2, 2021)

PH Client Alerts

Click here to read more from our Coronavirus series.

Legislation/Legislative Updates

Click here to view the full text of the Coronavirus Aid, Relief and Economic Security Act (the "CARES Act"), Enacted March 27, 2020.

Click here to view the full text of the Paycheck Protection Program Increase Act of 2020, Enacted April 24, 2020.

Click here to view the full text of the Paycheck Protection Program Flexibility Act of 2020, Enacted June 5, 2020.

Click here to view the full text of the Consolidated Appropriations Act, 2021, Enacted December 27, 2020.

Click here to view the full text of the American Rescue Plan of 2021, Enacted March 11, 2021.

Click here to view the full text of the PPP Extension Act of 2021, Enacted March 30, 2021.

Click here to view a running list of proposed legislation from the Senate Committee on Banking, Housing, and Urban Affairs, Senate Committee on Small Business and Entrepreneurship, House Committee on Financial Services, and House Committee on Small Business.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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