News & Analysis as of

Bank Holding Company Dodd-Frank Wall Street Reform and Consumer Protection Act

Certain Companies that May be Subject to FDIC Orderly Liquidation Authority under Dodd-Frank are Now Subject to Qualified...

by Dechert LLP on

Companies that the Financial Stability Oversight Council (FSOC) believes may be subject to FDIC receivership under the Orderly Liquidation Authority contained in Title II of the Dodd-Frank Act, and certain of their...more

US Board of Governors of the Federal Reserve System Releases CCAR Stress Test Scenarios for 2017

by Shearman & Sterling LLP on

The US Board of Governors of the Federal Reserve System released the scenarios to be used by banks and supervisors for the 2017 Comprehensive Capital Analysis and Review and stress test exercises (DFAST) mandated by the...more

Tailoring More Stringent Prudential Standards Under Section 165 of Dodd-Frank: Fed Finalizes Stress Test Relief for Large and...

by Morrison & Foerster LLP on

On January 30, 2017, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) adopted a final rule (the “Final CCAR Rule”) that revises the capital plan and stress test rules under the Dodd-Frank Wall...more

US House of Representatives Passes Legislation Eliminating $50 Billion Asset Threshold for SIFI Designation

by Shearman & Sterling LLP on

The US House of Representatives passed a bill (H.R. 6392) that would replace the current supervisory framework under the Dodd-Frank Act that automatically subjects all bank holding companies with $50 billion or more in total...more

US Federal Reserve Board Issues Proposal to Apply Existing Rating System for Bank and Savings and Loan Holding Companies

by Shearman & Sterling LLP on

The US Federal Reserve Board invited comment on a proposal to fully apply the Federal Reserve Board’s existing rating system for bank holding companies to savings and loan holding companies....more

OCC & Federal Reserve Report and Proposed Rules - Limitation on Banks Dealing & Investing in Metals and other Physical Commodities

by Reed Smith on

On September 8, 2016, as required by Section 620 of the Dodd-Frank Act, the Board of Governors of the Federal Reserve System (the “Board”), the Office of the Comptroller of the Currency (the “OCC”) and the Federal Deposit...more

Financial Regulatory Developments Focus - June 2016 #2

by Shearman & Sterling LLP on

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Nutter Bank Report, April 2016

The Nutter Bank Report is a monthly publication of the firm's Banking and Financial Services Group. Headlines 1. FDIC Approves Proposed Rule to Limit Incentive-Based Compensation Arrangements 2. Congress Considers...more

Federal Reserve Takes Aim at Shareholder Protections

by Locke Lord LLP on

In an unheralded Supervision and Regulation Letter (Letter) issued by the Board of Governors of the Federal Reserve System (Board) on December 3, 2015 (SR 15-15), the Board provided guidance to explain “Supervisory Concerns...more

FRB Requests Comments on Proposed Single-Counterparty Credit Limits

The Board of Governors of the Federal Reserve System ("FRB") has requested comments on reissued proposed rules that would establish a single-counterparty credit limits ("SCCL") for domestic and foreign bank holding companies...more

Another Brick in the Wall: The Fed Reproposes Single-Counterparty Credit Limits for Large Banking Organizations

by Morrison & Foerster LLP on

On March 4, 2016, the Board of Governors of the Federal Reserve System (the “Fed”) issued a Notice of Proposed Rulemaking (“NPRM”), inviting comment on reproposed rules (the “Reproposed Rules”) that would establish single...more

Mandatory Margin Posting Regulations Coming Soon for Uncleared Swaps

by Akerman LLP on

U.S. bank regulators recently adopted final rules establishing initial and variation margin requirements for uncleared swaps (Final Margin Rules). These rules apply to regulated entities such as banks and subsidiaries of bank...more

Too-big-to fail, RIP?

by Morrison & Foerster LLP on

The latest set of prudential rules is the strongest sign yet that too-big-to-fail has seen its last days - Despite the comprehensive reforms put in place in the wake of the financial crisis by the landmark Dodd-Frank...more

Federal Reserve Releases CCAR Scenarios; Banking Agencies Release Annual Company-Run Stress Test Scenarios

by Locke Lord LLP on

On January 28, 2016, the Federal Reserve released its supervisory scenarios for the 2016 Comprehensive Capital Analysis and Review (CCAR) and for the Dodd-Frank Act stress tests. In 2016, CCAR includes 33 firms with $50...more

Fed Finalizes Capital Planning, Stress Test Requirements for 2017

Why it matters - Capital planning and stress tests for bank holding companies and other institutions with assets over $10 billion have been finalized by the Federal Reserve Board of Governors. For bank holding companies...more

Financial Services & Products Advisory: Federal Reserve Releases Guidance on Shareholder Protection Arrangements

by Alston & Bird on

On December 3, 2015, the Board of Governors of the Federal Reserve System released Supervision and Regulation Letter 15-15, “Supervisory Concerns Related to Shareholder Protection Arrangements” (SR 15-15), offering guidance...more

TLAC, and Then Some… A Preliminary Assessment of the Federal Reserve Board’s NPR

by Morrison & Foerster LLP on

On Friday, October 30, 2015, the Federal Reserve Board (“Board”) reaffirmed its commitment to both the bank holding company model and single point of entry resolution. In a departure from historical views of the purpose and...more

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

by Pepper Hamilton LLP on

1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more

Fed Approves Rule Requiring Largest Banks To Further Strengthen Capital

The Federal Reserve Board approved a final rule requiring the largest, most systemically important U.S. bank holding companies to further strengthen their capital positions. Under the rule, a firm that is identified as a...more

The Federal Reserve Finalizes Capital Surcharge for Global Systemically Important Banks

by Shearman & Sterling LLP on

Today, the eve of the fifth anniversary of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Federal Reserve Board approved a final rule (“Final Rule”) establishing an additional risk-based capital surcharge...more

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

by Dechert LLP on

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

"New Provisions Require Structural Change for Foreign Banking Organizations"

The Enhanced Prudential Standards (Regulation YY) of the Board of Governors of the Federal Reserve System represent a significant shift in the U.S. regulation of foreign banking organizations (FBOs). In general, Regulation...more

House Takes Action to Delay Volcker Rule

by McGuireWoods LLP on

On Wednesday, the House passed a bill that would further delay the full implementation of the Volcker Rule – a highly controversial rule introduced under the Dodd-Frank Wall Street Reform and Consumer Protection Act that...more

Observation 2.0: The Anti-Evasion Provision of the Volcker Rule

by Pepper Hamilton LLP on

Overview This Client Alert continues Pepper’s observations on the Volcker Rule. Critical attention should be paid to the Volcker Rule’s anti-evasion provision, a powerful tool granted by Congress to the regulatory agencies to...more

Financial Services Weekly News Roundup - December 2014 #3

by Goodwin on

Amendment to Swaps Push-out Provision of Dodd-Frank: Section 630 of the recently passed Consolidated and Further Continuing Appropriations Act, 2015 (“Omnibus Spending Bill” – see p. 249) amends Section 716 of the Dodd-Frank...more

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