Bank Holding Company Federal Deposit Insurance Corporation

News & Analysis as of

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

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

Bank Regulators Issue Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards

Three federal banking regulatory agencies have approved an advance notice of proposed rulemaking (ANPR) inviting comment on a set of potential enhanced cybersecurity risk-management and resilience standards that would apply...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

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

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

LCR – The Fed Takes Tentative Step to Expand HQLAs

When the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “Board”) and the Federal Deposit Insurance Corporation (the “FDIC”) finalized the Liquidity Coverage...more

Financial Regulatory Developments Focus - February 2015

In this issue: - US Federal Deposit Insurance Corporation Issues Proposal Revising Provisions of Securitization Safe Harbor Rule - US Federal Deposit Insurance Corporation Issues Proposal Amending Regulations...more

Are You Fully Liquid? Liquidity Coverage Ratio Approved by Federal Reserve Board

We all know that liquids are both good and bad. We are supposed to drink on average eight glasses of water a day for good health. However, too much alcoholic intake will get us into trouble with the law. Now, the larger...more

Bank Holding Companies Must Review Their Tax Allocation Agreements With Subsidiary Banks Now!

Taxes remain a certainty in life, but in an effort to reduce confusion regarding the ownership of tax refunds—particularly in light of court opinions reaching varying conclusions when considering failed banks—the Board of...more

Federal Banking Agencies Issue Final Version of Addendum to Interagency Policy Statement on Income Tax Allocation

The FRB, FDIC and OCC (collectively, the “Agencies”) issued a final version of an addendum (the “Addendum”) to their “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure” (the “Policy...more

Bank Regulators Require Changes To Tax Allocation Agreements

Acting in response to divergent results in recent court decisions, the Federal bank regulatory agencies have adopted an Addendum to their longstanding rules regarding income tax allocation agreements between insured...more

FRB, FDIC and OCC Issue Final Rule Regarding Leverage Ratios for Largest Top-Tier Bank Holding Companies

On April 8, 2014, the FRB, FDIC and OCC (collectively, the “Agencies”) released a final rule (the “Final Rule”) concerning the leverage ratio standards for large, interconnected U.S. banking organizations. The Final Rule...more

Three Agencies Seek Comment on Joint Supplemental Guidance on Income Tax Allocation Agreements

On December 19, Fed, FDIC and OCC issued a statement seeking comment on supplemental guidance on income tax allocation agreements involving holding companies and insured depository institutions. ...more

Agencies Issue Proposed Guidance on Tax Allocation Agreements Between Insured institutions and Their Holding Companies

On December 19, banking agencies including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (collectively, the agencies)...more

Observation 1.1 On The Volcker Rule: Community Banks – Size Does Matter

On December 10, 2013, after more than three years of intensive development, the Board of Governors of the Federal Reserve System (FRB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation...more

FDIC Board Releases Single Point of Entry Resolution Strategy for Public Comment

On December 18, 2013, the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) published a widely anticipated notice in the Federal Register (the “Notice”) setting forth the FDIC’s single point of entry...more

CLOs Under the Volcker Rule: New Exemptions, New Issues, New Obligations

Under the final version of the Volcker Rule issued this week, issuers and sponsors of new CLO issuances should consider structuring CLOs to conform to the exclusions contained in the rule, and banks and bank affiliates that...more

Liquidity Coverage Ratio Impact on Covered Bonds

On October 23, 2013, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the “Agencies”) published a notice of proposed rulemaking...more

Agencies Provide Model Template For Submission Of Tailored Resolution Plans

The Federal Reserve Board and the Federal Deposit Insurance Corporation, or FDIC, have released an optional model template for tailored resolution plans that certain firms will be submitting for the first time later this...more

They’re Here: The Final Interagency Regulatory Capital Rules

The Federal Reserve Board today approved the publication of the long-awaited final regulatory capital rules (“Final Rules” ), which were proposed one year ago (the “Proposed Rules”). While today’s action was taken by the...more

Corporate and Financial Weekly Digest - May 17, 2013

In this issue: - CFTC Adopts Final Rules for Execution Facilities and Other Matters - FINRA Issues Interpretive Guidance on Use of Back Tested Index Data by ETPs - Mississippi District Court Defers to New...more

Are You Using Your Holding Company?

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

Update on Preparing Living Wills for Bank Holding Companies and Depository Institutions

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

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