News & Analysis as of

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

The Financial Report - Volume 3, No. 14 • July 24, 2014 (Global)

Discussion and Analysis - Monday of this week was the fourth anniversary of the signing of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Like all anniversaries, it is a time for looking back. As would...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

Prudential Regulators Propose Changes To Timing Of Stress Tests

On June 12, the Federal Reserve Board and the OCC separately released proposed rules that would push back by 90 days the start date of the stress test cycles and the deadlines for submitting stress test results....more

OCC’s Interim Volcker Rule Examination Procedures Provide Much-Needed Guidance to Banks Seeking to Comply

On June 12, 2014, the Office of the Comptroller of the Currency (OCC) issued interim procedures for examiners to assess banks’ progress in developing a framework to comply with the requirements of what is commonly known as...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

U.S. Federal Reserve Board Adopts Enhanced Prudential and Intermediate Holding Company Requirements for Foreign Banking...

The Federal Reserve Board (Board) recently adopted final rules representing the most significant change in U.S. regulation of foreign banking organizations (FBOs) since the International Banking Act of 1978. Perhaps most...more

Fed Seeks Public Comment on Financial Holding Company Physical Commodities Activities

An Advance Notice of Proposed Rulemaking (ANPR) issued in mid-January by the Federal Reserve Board (the Board) seeks public comment on the scope of permissible physical commodities activities. Such activities have been under...more

Fed Final Rule on Supervision and Regulation of Bank Holding Companies and Foreign Banks

On February 18, the Fed issued a final rule which establishes enhanced supervision standards for large U.S. bank holding companies and foreign banking organizations, as required by the Dodd-Frank Act. The final rule will be...more

Federal Reserve Board Finalizes Enhanced Prudential Standards For Large Bank Holding Companies, Foreign Banks

On February 18, the Federal Reserve Board issued a final rule that incorporates elements of two previously proposed rules related to U.S. bank holding companies with assets of $50 billion or more and foreign banking...more

Federal Reserve Approves Final Rule Regulating Bank Holding Companies and Foreign Banking Organizations

On February 18, the Federal Reserve Board (Federal Reserve) approved a Final Rule to enhance supervision over the largest US bank holding companies (BHCs) and the largest foreign banking organizations (FBOs) with operations...more

Despite the Best of Intentions, Paving the Way for the Next Financial Meltdown Part II: Getting Ready

As discussed in Part I of our Client Alert, “Despite the Best of Intentions, Paving the Way for the Next Financial Meltdown,” dated August 22, 2013, the Financial Stability Board (FSB) is studying the application of the key...more

Corporate and Financial Weekly Digest - Volume IX, Issue 8

In this issue: - OTC Markets Proposes Amendments to OTCQX Rules and New Rules for US Banks - SEC Approves Changes to FINRA BrokerCheck Disclosure Rule 8312 - SEC to Examine Never-Before Examined...more

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

FRB Issues ANPR Seeking Public Comment on Physical Commodity Activities Related to Physical Commodities Conducted by Financial...

The Federal Reserve Board (the “FRB” or the “Board”) issued an advance notice of proposed rulemaking (the “ANPR”) seeking public comment on issues related to activities concerning physical commodities conducted by financial...more

Upcoming TIC Form B Filing Deadline

The U.S. Department of Treasury recently amended the Treasury International Capital Form B (“Form B”), which imposes reporting obligations on some investment advisers to private funds. Form B generally requires the reporting...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

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

Fed Announcement of Supervisory Scenarios for Capital Planning and Stress Testing

On November 1, the Fed issued supervisory scenarios to be used for the 2014 capital planning and stress testing program, which includes the Comprehensive Capital Analysis and Review of 30 bank holding companies with $50...more

Federal Reserve Board Issues Rules On Incorporating Basel III Into Stress Tests

On September 24, the Federal Reserve Board issued two interim final rules that clarify how companies should incorporate the Basel III regulatory capital reforms into their capital and business projections during the next...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

Federal Reserve Issues Paper on Capital Planning and Rule for Assessments for Large Banks

On August 19, one day before issuing its notice of proposed rulemaking on bolstering leverage ratio standards (as discussed above in “Agencies Seek to Bolster Leverage Ratio Standards for Largest Banks”), the Board of...more

Federal Reserve Board Issues Final Large Bank Assessment Rule

On August 16, the Federal Reserve Board issued a final rule establishing the process by which it will assess annual fees for its supervision and regulation of large financial companies. The Dodd-Frank Act directed the Board...more

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