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Patomak Global Partners

Stress Test Results Keep Risk Management Capabilities in Focus

Situation Overview: The Federal Reserve Board (FRB) uses the stress tests as a key supervisory tool to explore risks across large banks. This year’s results quantified the impact to banks under multiple new scenarios,...more

Mayer Brown

Federal Reserve Wins Two Master Account Lawsuits

Mayer Brown on

At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more

Cadwalader, Wickersham & Taft LLP

Trends in 2024: American Bar Association Banking Law Committee Insights

From January 18th to 20th, the American Bar Association’s Banking Law Committee of the Business Law Section held its winter meeting in Washington, DC. This meeting not only provides an excellent retrospective of the previous...more

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Liquidity Risk Management and Preparation for Use of Discount Window

Last Friday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the ECB Forum on Banking Supervision in Frankfurt, Germany entitled The Importance of Effective Liquidity Risk...more

Troutman Pepper

FSOC Votes Unanimously to Finalize Process for Designating Nonbanks for Federal Reserve Supervision

Troutman Pepper on

On November 3, the Financial Stability Oversight Council (FSOC) voted unanimously to finalize the procedures for designating a nonbank financial company for Federal Reserve supervision. FSOC’s Interpretive Guidance aims to...more

Cadwalader, Wickersham & Taft LLP

FRB Governor Bowman Speaks on Financial Stability

Last week, Federal Reserve Board (“FRB”) Governor Michelle Bowman gave a speech entitled Financial Stability in Uncertain Times, focusing on the “financial stability risks and vulnerabilities” she is most focused on....more

Cadwalader, Wickersham & Taft LLP

Financial Kaleidoscope October 2023 - Fed Issues FAQs Clarifying That Credit-Linked Notes Can Serve as Valid Capital Relief Tools...

On September 28, the Federal Reserve Board (“FRB”) posted three new FAQs to its website regarding Regulation Q (Capital Adequacy of Bank Holding Companies, Savings and Loan Holding Companies, and State Member Banks). The FAQ...more

Cadwalader, Wickersham & Taft LLP

Fed Issues FAQs Clarifying That Credit-Linked Notes Can Serve as Valid Capital Relief Tools for U.S. Banks

On September 28, the Federal Reserve Board (“FRB”) posted three new FAQs to its website regarding Regulation Q (Capital Adequacy of Bank Holding Companies, Savings and Loan Holding Companies, and State Member Banks). The FAQ...more

Morrison & Foerster LLP

Federal Reserve Issues Guidance on Novel Activities, Including Bank-Fintech Partnerships

On August 8, 2023, the Board of Governors of the Federal Reserve System (FRB) issued two Supervision and Regulation Letters (“SR Letters”) that provide guidance on the agency’s supervision of novel activities and the process...more

Ballard Spahr LLP

Federal Reserve Board issues letters on program to supervise novel banking activities

Ballard Spahr LLP on

Earlier this month, the Federal Reserve Board (FRB) released two supervision and regulation letters regarding the agency’s program to supervise “novel” banking activities....more

Latham & Watkins LLP

FRB Clarifies Supervision of Digital Assets and Bank-Fintech Partnerships

Latham & Watkins LLP on

A new program addresses innovative banking activities such as bank-fintech partnerships and digital assets while reinforcing guardrails around stablecoin activity. On August 8, 2023, the Board of Governors of the Federal...more

Cadwalader, Wickersham & Taft LLP

FRB Governor Bowman Speaks on Bank Regulation and Supervision

Federal Reserve Board (“FRB”) Governor Michelle Bowman gave remarks last week to the American Bankers Association (“ABA”) Community Banking Conference. Governor Bowman discussed the role of FRB independence, predictability...more

Cadwalader, Wickersham & Taft LLP

Banking Agencies Issue Joint Statement on Crypto-related Liquidity Risks

Earlier yesterday, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”) issued a “Joint Statement on Liquidity Risks to Banking Organizations...more

Cadwalader, Wickersham & Taft LLP

FRB and OCC Release 2023 Stress Test Scenarios

The Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) last week released their 2023 Dodd-Frank Act Stress Test (“DFAST”) scenarios. As noted in the FRB’s release, the “stress tests help...more

Orrick, Herrington & Sutcliffe LLP

Agencies release hypothetical scenarios for 2023 bank stress tests

On February 9, the Federal Reserve Board and the OCC released hypothetical economic scenarios for use in the upcoming stress tests for covered institutions. The Fed released supervisory scenarios, which include baseline and...more

Cadwalader, Wickersham & Taft LLP

FRB Issues Policy Statement on Permissible Activities of State Member Banks While Denying Uninsured Crypto-focused Bank’s...

The Federal Reserve Board (“FRB” or “Board”) issued two seemingly related press releases late last week. The first announced the denial of the Federal Reserve membership application by Custodia Bank, a Wyoming special purpose...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Announces Pilot Climate Scenario Analysis Exercise Details

Last week, the Federal Reserve Board (FRB) announced additional details on its pilot climate scenario analysis (CSA) involving six of the largest U.S. banks. The additional details include a Participant Instructions Document...more

Cadwalader, Wickersham & Taft LLP

FRB Chair Powell Speaks on Central Bank Independence

Federal Reserve Board (“FRB”) Chair Jerome Powell spoke at a symposium hosted by the Swedish Central Bank on Tuesday. In his speech, Chair Powell highlighted three main points: (1) that Federal Reserve monetary policy...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Issues Final Rule Implementing LIBOR Act

On December 16, 2022, the Board of Governors of the Federal Reserve System (the “Board”) adopted a final rule (the “Final Rule”) to implement the Adjustable Interest Rate (LIBOR) Act (the “LIBOR Act”).  The Final Rule follows...more

Cadwalader, Wickersham & Taft LLP

FRB Proposes Climate-Related Financial Risk Management Principles

Recently, the Federal Reserve Board (“FRB”) proposed principles for climate-related financial risk management for large financial institutions. The proposed guidance is open for comment until 60 days after publication in the...more

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Capital Levels

On December 1, Federal Reserve Board (“FRB”) Vice Chair of Supervision Michael Barr gave a speech at the American Enterprise Institute on Bank Capital. Vice Chair Barr noted that the FRB’s holistic review of capital standards...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Issues Latest Financial Stability Report

At the end of last week, the Federal Reserve Board (“FRB”) issued its semi-annual Financial Stability Report. In a statement issued with the report, FRB Vice Chair Lael Brainard stated that over the past six months,...more

Cadwalader, Wickersham & Taft LLP

FRB and FDIC Issue Joint ANPR on Possible Resolution Requirements for Large Banking Organizations While FRB and OCC Approve U.S....

The Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) Board issued an Advanced Notice of Proposed Rulemaking (“ANPR”) titled “Resolution-Related Resource Requirements for Large Banking...more

Cadwalader, Wickersham & Taft LLP

FRB Governor Bowman Speaks on Banking Competition

On September 28, Federal Reserve Board (“FRB”) Governor Michelle Bowman spoke to the Community Banking Research Conference regarding the landscape for banking competition. Governor Bowman noted, as many have, that it is past...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Releases Large Bank Capital Requirements

Last week, the Federal Reserve Board (“FRB”) announced the individual capital requirements for all large banks, effective on October 1. This announcement follows the June announcement on the results of the supervisory stress...more

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