On October 24, 2023, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (together, the “Agencies”) released their final Principles for Climate-Related...more
The current banking crisis, which in significant part has been focused on regional banks catering to fintech companies, is likely to result in increasing regulatory focus on an industry already subject to regulatory scrutiny....more
One of the biggest challenges for fintechs is ensuring that their services comply with federal and state money transmission laws. For example, a fintech operating as a payment facilitator faces significant money transmission...more
The Board of Governors of the Federal Reserve (the "Federal Reserve") has over several decades defined when an activity engaged in by foreign banks subject to the Bank Holding Company Act of 1956 (the "BHCA"), which are thus...more
What happened? Just weeks before the real State of the Union Address to Congress, the Department of Defense (DoD or Department) published a report on the “State of Competition within the Defense Industrial Base” (DIB Report)....more
A United States District Court (Southern District – New York) (“Court”) addressed in a March 11th Opinion issues arising in a dispute between a County-owned airport and a fixed-based operator (“FBO”) regarding proposed...more
Since the 2008 financial crisis, a non-US bank seeking to establish or maintain a US presence has been required to comply with a set of stringent regulatory requirements, but a recently adopted rule (Final Rule) limits their...more
This installment of our monthly bid protest Law360 spotlight takes a look at three protest decisions from August, highlighting the most noteworthy aspects of the decisions for companies competing for contracts and agencies...more
With the regulatory agenda for the US operations of foreign banks in a state of flux, Kevin Petrasic, Paul Saltzman, Glen Cuccinello, Will Giles and Alexander Abedine of global law firm White & Case provide a map to help...more
On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more
The US Federal Reserve Board announced that it is seeking comments regarding a proposed change to its Payment System Risk Policy. In a related action, the Federal Reserve Board has also announced that it is eliminating the...more
LawFlash February 17, 2017 Financial Services Agency of Japan proposes seven principles aimed at creating a customer-oriented financial services culture. On January 19, the Financial Services Agency of Japan (JFSA) released a...more
SEC Adopts Trade Acknowledgment and Verification Rules for Security-Based Swap Transactions - On June 8, 2016, the Securities and Exchange Commission publicized the implementation of "rules that will establish timely and...more
On June 8, 2016, the Federal Reserve updated its Supervisory Guidance that partially supersedes SR letter 95-51, “Rating the Adequacy of Risk Management and Internal Controls at State Member Banks and Bank Holding Companies.”...more
On June 10, 2016, the Federal Reserve Board and Federal Deposit Insurance Corporation announced they are permitting 84 foreign banking organizations (not identified) with limited U.S. operations to file “reduced content”...more
On Monday, April 4, 2016, the Board of Governors of the Federal Reserve System (“Federal Reserve”) proposed a revision to Form FR Y-7Q to incorporate the capital adequacy standard reporting requirements for foreign banking...more
The latest set of prudential rules is the strongest sign yet that too-big-to-fail has seen its last days - Despite the comprehensive reforms put in place in the wake of the financial crisis by the landmark Dodd-Frank...more
On Friday, October 30, 2015, the Federal Reserve Board (“Board”) reaffirmed its commitment to both the bank holding company model and single point of entry resolution. In a departure from historical views of the purpose and...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
A property tax exemption designed to benefit a single aviation company was recently found unconstitutional by the Illinois Appellate Court. The exemption was only for fixed base operators (FBOs) providing aeronautical...more
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 contains two sets of provisions for managing the insolvency of financial institutions. First, the legislation creates an Orderly Liquidation Authority...more
The five agencies that jointly issued the final Volcker Rule last December recently added to their existing list of “frequently asked questions” (FAQs) a new item addressing the attestation requirement applicable to CEOs of...more
On June 26, 2014, the Federal Reserve Board (“Board”) published on its website responses to frequently asked questions (“FAQs”) relating to enhanced prudential standards under Section 165 of the Dodd-Frank Act and its...more
The notorious regulation technically took effect on April 1. Covered entities must now pay closer attention to how they structure their trading activities, and their investments in fund-type vehicles. Perhaps not...more
Last week, the Federal Reserve Board (the “Board”) issued its long-awaited final enhanced prudential rule (Regulation YY) under Section 165 of the Dodd-Frank Act (the “Final Rule”) for bank holding companies and foreign...more