News & Analysis as of

Banking Sector Federal Reserve

Orrick, Herrington & Sutcliffe LLP

Fed’s Barr speaks on changes to Basel III and liquidity requirements

On September 10, the Fed released the prepared remarks given by the Vice Chair for Supervision, Michael Barr, on changes to the Basel III endgame proposal and the capital surcharge for global systemically important banks...more

Orrick, Herrington & Sutcliffe LLP

Fed issues cease and desist against bank

On September 4, the Fed and the Texas Department of Banking published a cease and desist order alleging deficiencies identified in a Texas-based bank’s corporate governance, risk management and compliance with BSA/AML laws....more

Sheppard Mullin Richter & Hampton LLP

Fed Issues Cease and Desist Order for Crypto-Related Compliance and Risk Management Deficiencies

On September 4, the Federal Reserve Board (Fed) released enforcement actions against a Texas-based bank, addressing regulatory violations and compliance lapses. The Fed, joined by the Texas Department of Banking (TDB),...more

Pillsbury - Global Sourcing Practice

U.S. Financial Regulators Continue Focus on Bank-Fintech Partnerships through Guidance and Request for Information

On July 25, 2024, the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a joint statement describing potential...more

Paul Hastings LLP

Daily Financial Regulation Update -- Thursday September 5

Paul Hastings LLP on

September 4, 2024- The Federal Reserve Bank of New York published a Liberty Street Economics blog post entitled “AI and the Labor Market: Will Firms Hire, Fire, or Retrain?” September 4, 2024- The Bank Policy Institute...more

Orrick, Herrington & Sutcliffe LLP

Fed issues enforcement action against bank holding company

On August 15, the Fed released an enforcement action against a registered bank holding company and its parent company alleging financial and governance concerns. The agreement established concrete steps and regulatory...more

Orrick, Herrington & Sutcliffe LLP

Fed releases final capital requirements for all large banks

On August 28, the Fed released its final capital requirements for large bank holding companies. As previously covered by InfoBytes, the Fed derived these requirements from stress test results showing that large banks had...more

Orrick, Herrington & Sutcliffe LLP

Financial agencies propose rules to standardize data collections

On August 2, the OCC, Fed, FDIC, NCUA, CFPB, FHFA, CFTC, SEC and Treasury (collectively, the agencies) released an interagency NPRM to establish data standards across these agencies for “certain collections of information...more

Orrick, Herrington & Sutcliffe LLP

FDIC, Fed approve final resolution planning guidance

On July 30, the Fed and the FDIC published final guidance to enhance resolution planning at large banks. The guidance aims to assist certain larger financial institutions in developing their resolution plans, which are...more

Cadwalader, Wickersham & Taft LLP

FDIC Proposes To Exercise Now-Dormant Authority Under the Change-in-Bank Control Act

The board of directors of the Federal Deposit Insurance Corporation (“FDIC”) recently proposed a rule change that would reassert its now-dormant authority to review changes in bank control involving bank holding companies....more

Paul Hastings LLP

Daily Financial Regulation Update -- Friday August 9

Paul Hastings LLP on

August 8, 2024- The Federal Reserve and U.S. Treasury did not intervene in foreign exchange markets during the April – June 2024 quarter, the Federal Reserve Bank of New York said in its quarterly report to the U.S....more

Latham & Watkins LLP

FDIC Proposes Amendments to Its Change in Bank Control Act Regulations

Latham & Watkins LLP on

The proposal would establish stricter oversight of certain transactions and responds to concerns that large asset managers may be exerting influence on FDIC-supervised institutions. On July 30, 2024, the Board of...more

MoginRubin LLP

Why the Capital One-Discover Merger Makes Sense

MoginRubin LLP on

When federal agencies review bank mergers, the competition issues typically relate to the number and location of physical branches and the extent of any overlap in the areas served. By contrast, the proposed $35 billion...more

Sheppard Mullin Richter & Hampton LLP

Federal Regulators Issue Joint Statement and Request for Information Emphasizing Caution with BaaS Model

On July 25, federal regulators issued a joint statement to further put banking organizations on notice of the inherent risks of collaborating with fintechs in offering deposit products and services. This guidance aims to...more

Orrick, Herrington & Sutcliffe LLP

Bank regulators appeal to 5th Circuit to lift district court’s final rule ban

On July 18, the OCC, FDIC, and the Fed (the federal banking agencies or FBAs) submitted a brief requesting that the U.S. Court of Appeals for the Fifth Circuit hold oral argument and reverse the U.S. District Court for the...more

Orrick, Herrington & Sutcliffe LLP

Fed’s 2024 stress test results show a robust banking system

Recently, the Fed released the 2024 Federal Reserve Stress Test Results and found that the tested banks have “sufficient capital” to absorb losses and weather a recession while staying above minimum capital requirements. The...more

Orrick, Herrington & Sutcliffe LLP

FDIC, Fed, and OCC announce 2024 CRA-eligible distressed and underserved areas

On July 12, the FDIC, Fed, and OCC released a list of distressed or underserved nonmetropolitan middle-income areas eligible for CRA credit. The list identified regions where banks’ revitalization or stabilization activities...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 40: Financial Innovation and Supervision

RegFi co-hosts Jerry Buckley and Caroline Stapleton welcome podcast guest Tracy Basinger, former head of supervision at the Federal Reserve Bank of San Francisco and a senior advisor at the Klaros Group. Tracy brings a unique...more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Opens the Door to More Rule Challenges by Extending Accrual Date for APA Cases

In Corner Post v. Board of Governors of the Federal Reserve System, the U.S. Supreme Court held the six-year statute of limitations under 28 U.S.C. §2401 for challenging federal agency action under the Administrative...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more

Cadwalader, Wickersham & Taft LLP

The U.S. Basel III Endgame Proposal: Update and Thoughts

On September 18, 2023, the U.S. Basel III Endgame proposal was published in the Federal Register. The comment period ended on January 16, 2024, with the banking regulators (the Federal Reserve, the OCC, and the FDIC) having...more

Orrick, Herrington & Sutcliffe LLP

Agencies issue host state loan-to-deposit ratios

On May 31, the FDIC, Fed, and OCC (the agencies) released the current host state loan-to-deposit ratios for each state or territory, which the agencies used to determine compliance with Section 109 of the Riegle-Neal...more

Kilpatrick

Bank Regulators Revive Proposed Rules on Incentive Pay

Kilpatrick on

Three federal regulators have reproposed rules that implement the requirements for bank incentive compensation programs that were included in the Dodd-Frank legislation 14 years ago. Section 956 of Dodd-Frank required the...more

Poyner Spruill LLP

Trends in a “Pray and Delay” Economy

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2023 and the start of 2024 presented challenging economic conditions to the market, with debt costs at a historic high.  Following a series of increases over the last two years, the Federal Reserve’s federal funds rate is...more

Latham & Watkins LLP

FRB Issues Report on Climate Scenario Analysis Pilot

Latham & Watkins LLP on

With regulators keeping close watch, the results underscore the need for ongoing climate risk management investment and adaptation within the financial sector. On May 9, 2024, the Board of Governors of the Federal...more

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