Do Banks Still Need Holding Companies?
The Board of Governors of the Federal Reserve System (the Board) issued a much-anticipated final rule (Final Rule) on January 30 to amend and codify—in certain respects, for the first time—its framework for making...more
Many private equity, hedge and mutual funds constantly have to confront the complex control rules that may impact even the smallest of investments in banks or bank holding companies (BHCs). The issue may be as simple as...more
The U.S. Federal Reserve Board (FRB) has become sensitized to safety and soundness concerns relating to shareholder protection arrangements. These arrangements are generally designed to protect existing shareholders of bank...more
On Friday, March 4, 2016, the Volcker Inter-Agency Group posted a new frequently asked question (FAQ 21), clarifying the capital deduction requirement under the Volcker Rule for investments in Qualifying TruPS CDOs. FAQ 21...more
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
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