On April 18 the Federal Reserve Board (Board) proposed an annual assessment of bank holding companies and savings and loan holding companies with $50 billion or greater in total consolidated assets and for nonbank financial...more
On April 15, the Federal Reserve Board proposed a rule that would establish an annual assessment for bank holding companies and savings and loan holding companies with $50 billion or more in total consolidated assets and for...more
In this issue: - FINRA and ISG Extend Effective Date for Certain Electronic Blue Sheet Data Elements - NFA Amends FCM Capital Requirements for Forex Transactions with ECPs - Delaware Supreme Court Upholds...more
The Federal Reserve Board has approved a final rule that establishes the requirements for determining when a company is “predominantly engaged in financial activities.” The requirements will be used by the Financial Stability...more
Background - On 26 December 2012 (the “Effective Date”), Bank Indonesia (“BI”) published Regulation No. 14/24/PBI/2012 (“Regulation 14”) which contains a revised version of the single presence policy applicable to...more
Many banks formed holding companies in the late 1980s and 1990s. They had various reasons for doing this. Some formed a holding company to hold subsidiaries providing nonbank activities. Some used the holding company to...more
In This Issue: - Conversation with a Community Banking Professional: Ginger Salt of First Community Bank - Are You Using Your Holding Company? - Shifting Winds? Two N.C. Courts Uphold Fiduciary Duty...more
The Federal Reserve Board last month proposed new rules intended to strengthen the oversight of U.S. operations of foreign banks. The proposal implements provisions of the Dodd-Frank Wall Street Reform and Consumer Protection...more
This analysis updates a previous memo and incorporates advice we have received from the Federal Reserve Board (“FRB”) and the Federal Deposit Insurance Corporation (“FDIC”) regarding the preparation of living wills for bank...more
The Federal Reserve Board on January 28 announced that results from the supervisory stress tests conducted as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act will be released on Thursday, March 7, and...more
While several foreign banking organizations (“FBOs”) were restructuring their U.S. presence to reduce the impact of U.S. regulation, the Board of Governors of the Federal Reserve System (“Board”) recently countered with...more
On December 28, the U.S. Court of Appeals for the Fourth Circuit affirmed a district court holding that a bankruptcy trustee lacked standing to sue former directors of an insolvent bank holding company for alleged...more
The Board of Governors of the Federal Reserve System (“Board”) has devoted some time to considering how to address the potential threat to the financial stability of the United States posed by a foreign bank with banking...more
The JOBS Act contains a provision that community banks have long desired – an increase in the number of shareholders that a bank or a bank holding company can have before it is required to register its shares with the...more
The JOBS Act increased the threshold of registration under Section 12(g) of the Exchange Act from 300 to 1,200 persons. The JOBS Act does not on its face provide relief from Exchange Act reporting requirements under Section...more
Section 606 of the Dodd-Frank Act adds a new standard for a bank holding company (BHC) which elects to become, or already is, a financial holding company (FHC). Now, in order for a BHC to elect or maintain FHC status, not...more
The passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Bill”) represents the most ambitious and thorough regulatory reform of the laws governing the financial industry since the Great Depression....more
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