Federal Reserve

News & Analysis as of

Prudential Regulators Finalize Liquidity Coverage Ratio Rule

On September 3, the OCC, the FDIC, and the Federal Reserve Board released a final rule establishing a minimum liquidity requirement for large and internationally active banking organizations. The rule will require banking...more

Prudential Regulators Seek Comments On Proposed CRA Questions And Answers

On September 8, the OCC, the FDIC, and the Federal Reserve Board released proposed revisions to the Interagency Questions and Answers Regarding Community Reinvestment. Specifically, the agencies propose to revise three...more

Prudential Regulators Finalize Supplementary Leverage Ratio Rule

On September 3, the OCC, the FDIC, and the Federal Reserve Board released a final rule that modifies the definition of the denominator of the supplementary leverage ratio in a manner consistent with recent changes agreed to...more

Financial Services Report - Fall 2014

In This Issue: - Beltway Report - Bureau Report - Mobile and Emerging Payments Report - Mortgage and Fair Lending Report - Operations Report - Preemption Report - Privacy...more

Banking Agencies Request Comment on Proposed Questions and Answers Regarding Community Reinvestment

On September 8, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency requested comment on proposed revisions to the “Interagency...more

Federal Reserve and CFPB Announce Increases in Dollar Thresholds in Regulations Z and M for Exempt Consumer Credit and Lease...

On September 9, the Federal Reserve Board and the Consumer Financial Protection Bureau (CFPB) announced increases in the dollar thresholds in Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) for exempt...more

Merchants Ask Supreme Court to Consider Interchange Fees

A coalition of merchants and retailers has requested that the U.S. Supreme Court weigh in on interchange fees. In March, the D.C. Circuit Court of Appeals upheld the rules promulgated by the Board of Governors of the...more

Orrick's Financial Industry Week in Review

Council of EU Presidency Compromise Proposal on Benchmark Regulation - On September 10, the Presidency of the Council of the EU published its first compromise proposal (dated September 9, 2014) relating to the European...more

Banks May Be Required to Increase Reserves

The Federal Reserve is expected to require the biggest U.S. banks to increase reserves in an effort to prevent the possibility of another financial crisis. Federal Reserve Governor Daniel K. Tarullo is scheduled to testify...more

House members propose bill to nullify CFPB indirect auto finance guidance

A bipartisan group of fourteen House members have introduced a bill (H.R. 5403) that would nullify the CFPB’s indirect auto finance guidance issued in March 2013 and require the CFPB to provide for a notice and comment period...more

CFPB and Fed announce increases in Regs Z and M 2015 dollar thresholds

The CFPB and Fed have announced increases in the dollar thresholds in Regulation Z (Truth in Lending Act) and Regulation M (Consumer Leasing Act) for exempt consumer credit and lease transactions. The adjustments reflect the...more

Federal Banking Regulators Finalize Liquidity Coverage Ratio

On September 3, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency finalized a rule to strengthen the liquidity positions of large financial institutions.The...more

What’s Unfair is Unfair: Repeal of Reg AA May Have Little Practical Effect

The Federal Reserve Board (Board) issued a notice of proposed rulemaking on August 22, 2014 (Notice) for the repeal of Regulation AA, which is the Board’s credit practices rule prohibiting certain unfair or deceptive acts and...more

Comments requested regarding proposed guidance on the Community Reinvestment Act

The Office of the Comptroller of the Currency, Treasury, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation are the federal agencies that implement the Community Reinvestment...more

Banking Agencies Adopt Supplementary Leverage Ratio Final Rule

On September 3, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency adopted a final rule modifying the definition of the denominator of the supplementary...more

AABD Makes Suggestions to Regulatory Agencies Regarding The Burdens Placed On America’s Bank Directors

On September 2, David Baris, President of the American Association of Bank Directors (AABD) and a Partner at BuckleySandler LLP, and Richard Whiting, Executive Director of the AABD, submitted a comment letter to the Nation’s...more

CFPB issues updated guides on the TILA-RESPA Integrated Disclosure Rule

The CFPB has released its updated Small Entity Compliance Guide for the TILA-RESPA Integrated Disclosure Rule and Guide to the Loan Estimate and Closing Disclosure. These resources replace the editions that were published in...more

Federal Banking Regulators Finalize Liquidity Coverage Ratio

On September 3, the FDIC, the Fed, and the OCC finalized the Liquidity Coverage Ratio rule to strengthen the liquidity positions of large financial institutions. The rule will for the, first time, create a standardized...more

Federal Agencies Seek Comment on Swap Margin Requirements

On September 3, the Fed, the Farm Credit Administration, the FDIC, the FHFA, and the OCC sought comment on a proposed rule to establish margin requirements for swap dealers, major swap participants, security-based swap...more

Orrick's Financial Industry Week in Review

ESMA Publishes Guidelines on the EU Implementation of CPSS-IOSCO Principles - On September 4, ESMA published the translation of guidelines and recommendations on implementing the principles for financial market...more

FRB Issues Proposed Rules to Repeal Regulation AA, as Required by Dodd-Frank

On Wednesday, August 27, the Board of Governors of the Federal Reserve System (the “Board”) published in the Federal Register proposed rules and a request for public comment to repeal its Regulation AA (Unfair or Deceptive...more

Are You Fully Liquid? Liquidity Coverage Ratio Approved by Federal Reserve Board

We all know that liquids are both good and bad. We are supposed to drink on average eight glasses of water a day for good health. However, too much alcoholic intake will get us into trouble with the law. Now, the larger...more

Summary of Prudential Regulators’ Re-Proposed Margin Rules

On September 3, the Board of Governors of the Federal Reserve System (“Board”), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Farm Credit Administration and the Federal Housing...more

Interagency Guidance Regarding Unfair Or Deceptive Credit Practices

On August 22, the CFPB and the federal banking agencies (Fed, OCC, FDIC and NCUA) issued interagency guidance regarding unfair or deceptive credit practices (UDAPs). The guidance clarifies that “the repeal of the credit...more

Do Guarantors Fall under the Protection of the Equal Credit Opportunity Act?

We have discussed the Equal Credit Opportunity Act (“ECOA”), which makes it unlawful for a creditor to discriminate against an applicant in any aspect of a credit transaction on the basis of, among other things, the...more

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