The Situation: The regulatory agencies responsible for administering the Volcker Rule have amended the covered fund provisions of the rule. The Result: Modifications to the definitions of "ownership interest" and "loan...more
Last week the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity Futures...more
The Federal Reserve took the rare step yesterday of stepping “into financial markets . . . to keep interest rates from rising above its target, the first time the central bank has had to carry out this type of ‘market...more
In This Issue: - RECENT CASES ..Preemption ..CFPB Involvement in Litigation ..CFTC Regulation of Retail Commodity Transactions ..Durbin Amendment ..Appraiser Disclosure Requirements Under...more
On December 10, 2013, the Board of Governors of the Federal Reserve System, Commodity Futures Trading Commission, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and Securities Exchange...more
Last week, the five agencies that jointly issued the final regulation implementing the Volcker Rule (the Final Rule) in December issued an interim final rule (the Interim Rule) that exempts collateralized debt obligations...more
On January 14, the Fed, CFTC, FDIC, OCC and SEC issued an interim final rule which will permit banking entities to retain interests in certain collateralized debt obligations backed primarily by trust preferred securities...more
The Volcker Rule (“Volcker Rule” or “Rule”) is intended to limit risks to the financial system that Congress believes may be created by (i) proprietary trading operations of insured depository institutions, foreign banking...more
In Observation 1.1.1, we discussed the surprise treatment under the new Volcker Rule regulations of collateral debt obligations (CDOs) backed by trust preferred securities (TruPS) as “covered funds,” which would force banking...more
On December 10, 2013, the federal banking agencies jointly issued final regulations to implement the “Volcker Rule,” added to the Bank Holding Company Act by Section 619 of the Dodd-Frank Act, to prohibit banking entities and...more
The FRB, the FDIC, and the OCC (the “Agencies”) issued a joint FAQ clarifying certain aspects of the treatment of interests in collateralized debt obligations backed by trust preferred securities (“TruPS CDOs”) under the...more