News & Analysis as of

Federal Reserve Issues Guidance on Implementation Plans and Other Enhanced Prudential Standards for Foreign Banking Organizations

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 Volcker Rule: Overview and Recent Developments Affecting Banking Entities, Funds and Securitization Vehicles

Following years of incubation, in December 2013, five U.S. regulatory agencies – the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the...more

Fed Proposes Concentration Limits for Financial Institution M&A

The Federal Reserve Board has issued a proposed rulemaking that would implement Section 622 of the Dodd-Frank Act, which prohibits a financial company from combining with another company if the ratio of the resulting...more

Federal Reserve Board Finalizes Rule Amending Red Flags Rule

The FRB repealed its several regulations including Regulation DD, Truth in Savings and, Regulation P, Privacy of Consumer Financial Information. The Dodd-Frank Act granted rulemaking authority for a number of consumer...more

Federal Reserve Board Repeals Duplicative Regulations, Finalizes Red Flag Rule Amendments

On May 22, the Federal Reserve Board repealed its Regulation DD, which implements TISA, and Regulation P, which implements Section 504 of the GLBA because the Dodd-Frank Act transferred rulemaking authority for those laws to...more

Final Volcker Rule Places More Emphasis on Compliance Programs

Following over two years of comment and debate, the final Volcker Rule officially went into effect on April 1, 2014. While most banks have until July 21, 2015 to reach Volcker Rule compliance, those with over $50 billion in...more

Dodd-Frank News: May 2014: Dodd-Frank Wall Street Reform and Consumer Protection Act Update

In This Issue: - RECENT CASES ..Preemption ..CFPB Involvement in Litigation ..CFTC Regulation of Retail Commodity Transactions ..Durbin Amendment ..Appraiser Disclosure Requirements Under...more

Do Dodd-Frank's Stress Testing Results Hold Hidden Risks?

While the recent Dodd-Frank stress test results of the nation's 30 biggest banks might seem reassuring, prudent policy makers and practitioners should be wary. Like airport security, many are asking, ‘‘Are we...more

FRB Issues Proposed Rule Implementing Dodd-Frank Act’s Concentration Limit on Large Financial Companies

The FRB issued a notice of proposed rulemaking (the “Proposed Rule”) that would implement section 622 (“section 622”) of the Dodd-Frank Act, which established a financial sector concentration limit (the “Concentration Limit”)...more

Federal Reserve Board Proposes Liability Concentration Limit

On May 8, the Federal Reserve Board released a proposed rule that would prohibit certain financial companies from combining with another company if the resulting financial company’s liabilities would exceed 10% of the...more

FIO Focus, Issue No. 51: Legislation Introduced to Clarify Collins Amendment

Concerns that minimum leverage and risk-based capital requirements required under section 171 of the Dodd-Frank Act would be applied to insurance companies have been addressed in S. 2270, sponsored by Susan Collins (R-ME),...more

Key issues for asset managers in 2014

In this newsletter - U.S.: - Dodd-Frank Act – Designation of asset managers as systemically important financial institutions - Volcker Rule finalised with a more limited application to covered fund activities...more

Banking Agencies Issue Proposed Rules for Appraisal Management Companies, as Required under Dodd-Frank

On Wednesday, April 9, 2014, the Office of the Comptroller of the Currency, the Federal Reserve System, the Federal Deposit Insurance Corporation, the Consumer Financial Protection Bureau and the Federal Housing Finance...more

Federal Reserve Board Announces Volcker CLO Conformance Period Extension

On April 7, the Federal Reserve Board issued a statement that it intends to exercise its authority to give banking entities two additional one-year extensions to conform their ownership interests in, and sponsorship of,...more

Agencies Issue Interim Final TruPs CDOs Rule, Effective April 1

On January 14, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission and the...more

Banking balkanisation?

In mid-February 2014, the Federal Reserve approved the final enhanced prudential rule for foreign banking organisations (FBOs) under Section 165 of the Dodd-Frank Act. The final rule applies enhanced standards to FBOs that...more

Enhanced Prudential Standards for Foreign Banking Organizations: The US Approach to Ring-Fencing

The Board of Governors of the Federal Reserve System (“Board”) on February 18, 2014 adopted a final rule (“Final Rule”) to implement enhanced capital, liquidity and other prudential standards for foreign banks with US...more

Bankers Win Latest Interchange Battle

The U.S. Court of Appeals for the District of Columbia Circuit recently reversed a lower court decision and upheld the interchange rules adopted by the Federal Reserve Board (FRB) under the so-called Durbin Amendment to the...more

Prudential Regulators Finalize Midsize Bank Stress Test Guidance

On March 5, the Federal Reserve Board, the OCC, and the FDIC issued final guidance for stress tests conducted by banking institutions with more than $10 billion but less than $50 billion in total consolidated assets. Under...more

Fed Seeks Public Comment on Financial Holding Company Physical Commodities Activities

An Advance Notice of Proposed Rulemaking (ANPR) issued in mid-January by the Federal Reserve Board (the Board) seeks public comment on the scope of permissible physical commodities activities. Such activities have been under...more

Final Guidance for Medium-Sized Firms on Dodd-Frank Stress Tests

On March 5, the Fed, the FDIC, and the OCC issued final guidance which describes supervisory expectations for stress tests to be conducted by financial companies with between $10 and $50 billion in total assets. The guidance...more

Dodd-Frank: Enhanced Supervision Becomes Final

The Federal Reserve’s proposed requirements for large US and non-US banking organizations to comply with enhanced supervisory requirements, required by Section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection...more

Final Federal Reserve Rules for Foreign Banking Organizations

This Alert describes the final regulations issued by the Federal Reserve Board (the “FRB”) on February 18, 2014, that radically modify the former requirements applicable to foreign banking organizations (“FBOs”) pursuant to...more

Private Fund Update - March 3, 2014

In this issue: - The 113th Congress - The Administration - Securities and Exchange Commission - Commodity Futures Trading Commission (CFTC) - Association for Corporate Growth (ACG) -...more

Federal Reserve Finalizes U.S. and Foreign Bank Prudential Standards

The long-awaited standards establish significant structural, liquidity, risk management, and capital requirements for the largest U.S. and foreign banks operating in the United States, including new intermediate holding...more

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