News & Analysis as of

Banking Bulletin: Regulators To Mandate Amendments To Tax Allocation Agreements

On December 19, 2013, the Federal Reserve, OCC, and FDIC issued a Proposed Addendum to the Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure. The agencies are currently soliciting comments,...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

Federal Regulators Release Tailored Resolution Plan Template

On September 3, the Federal Reserve Board and the FDIC released an optional model template for firms to use when preparing the tailored resolution plans required from some bank and nonbank entities under Dodd-Frank. Entities...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

Prudential Regulators Propose Leverage Ratio Rule

On August 20, the Federal Reserve Board, the OCC, and the FDIC proposed a rule to strengthen the leverage ratio standards for the largest U.S. banking organizations. The proposed rule is the same as that approved last month...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

Fourth Circuit Holds Bankruptcy Trustee Cannot Pursue Former Directors Of Bankrupt Holding Company For Alleged Mismanagement Of...

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

Dodd-Frank Bill Reshapes Businesses

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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