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News & Analysis as of

LCR – The Fed Takes Tentative Step to Expand HQLAs

When the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “Board”) and the Federal Deposit Insurance Corporation (the “FDIC”) finalized the Liquidity Coverage...more

OCC, FRB, and FDIC Push Ahead on Reducing Regulation of Community Banks

On May 4, 2015, Comptroller of the Currency Thomas Curry, Federal Reserve Board (FRB) Governor Daniel Tarullo, and Federal Deposit Insurance Corporation (FDIC) Chairman Martin Gruenberg held the third in a series of outreach...more

Orrick's Financial Industry Week in Review

CFTC Issues Guidance for Swap Execution Facilities on the Calculation of Projected Operating Costs - On April 23, the CFTC issued guidance regarding the calculation of projected operating costs or expenses for the...more

Federal Bank Supervisory Agencies May Change Guidance Without Notice-and- Comment Rulemaking

New rulemakings to implement financial reforms leave banking organizations facing a host of uncertainties. Guidance or “interpretative rules” from the financial regulators on the intended scope and application of new rules...more

Federal Banking Agencies Seek Comment on Proposed Market Risk Regulatory Report

On February 18, three federal banking agencies – the Federal Reserve Board, OCC, and FDIC – issued a joint notice seeking public comments on a proposed information collection form and its reporting requirements, FFIEC 102 –...more

Federal Guidance: 6 Principles for Banks Originating Student Loans with Graduated Payments

On January 29, five federal regulatory agencies (Consumer Financial Protection Bureau, Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and...more

Guidance on Private Student Loans With Graduated Repayment Terms Released

On January 29, federal financial regulatory agencies in partnership with the State Liaison Committee (SLC) of the Federal Financial Institutions Examination Council, issued guidance for financial institutions on private...more

Financial Regulatory Developments Focus - February 2015

In this issue: - US Federal Deposit Insurance Corporation Issues Proposal Revising Provisions of Securitization Safe Harbor Rule - US Federal Deposit Insurance Corporation Issues Proposal Amending Regulations...more

CFPB seeks information from industry on student loan modification options and issues guidance on private student loans with ...

As a follow up to a January 2014 meeting with private student loan lenders and servicers convened by Director Cordray and Education Secretary Arne Duncan, the CFPB sent letters last week to certain “market participants”...more

Regulators Release Guidance on Private Student Loans With Graduated Repayment Terms at Origination

On January 29, the federal financial regulatory agencies (the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union...more

"Lawmakers and Regulators Continue Focus on Strategies for Resolving SIFIs"

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

Bank Regulators Release Public Sections of “Living Wills”

On January 15, the Federal Reserve and the FDIC issued a joint press release making available the public sections of resolution plans of firms with less than $100 billion in qualifying nonbank assets. The Dodd-Frank Act...more

Fed Issues Volker Rule FAQs

The Federal Reserve Board has issued FAQs on the Volker Rule set forth in Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The FAQs mirror other FAQs issued by Office of the Comptroller of the...more

Financial Regulatory Developments Focus - December 2014 #5

In this issue: - Bank Prudential Regulation & Regulatory Capital - Consumer Protection - Credit Ratings - Enforcement - Funds - Excerpt from Bank Prudential Regulation &...more

Orderly Unwinding: Here to Stay?

The International Swaps and Derivatives Association (ISDA) recently issued the ISDA 2014 Resolution Stay Protocol (Protocol), which takes effect on 1 January 2015. The Protocol aims to prevent adhering parties from...more

New Law Limits the Swaps Pushout Requirement to Apply Only to Certain ABS Swaps

On December 16, 2014, President Barack Obama limited the scope of swaps and security-based swaps subject to the Dodd-Frank Wall Street Reform and Consumer Protection Act’s (“Dodd-Frank Act’s”) pushout requirement to certain...more

FFIEC Releases Revised BSA/AML Examination Manual

On November 26, the Federal Financial Institutions Examination Council (FFIEC) released the revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. ...more

Financial Regulatory Developments Focus - December 2014 #2

In this issue: - Bank Prudential Regulation & Regulatory Capital - Bank Structure - Derivatives - Financial Market Infrastructure - Financial Services - People - Events...more

Update on Leveraged Lending Guidance; November 24, 2014

On November 7, the Federal Reserve, FDIC and OCC jointly published answers to Frequently Asked Questions (“FAQs”) about the implementation of the March 2013 Interagency Guidance on Leveraged Lending. Highlights of the FAQs...more

Financial Regulatory Developments Focus - November 2014 #4

In this issue: - Bank Prudential Regulation & Regulatory Capital - Bank Structure - Compensation - Consumer Protection - Derivatives - Enforcement - Financial Market...more

Orrick's Financial Industry Week in Review

Bank of America and Merrill Lynch Settle RMBS Lawsuit with FDIC - On November 17, Bank of America and Merrill Lynch settled securities claims brought by the FDIC related to RMBS sold to United Western Bank. The FDIC,...more

Agencies Propose Technical Corrections and Clarifications to the Capital Rules Applicable to Advanced Approaches Banking...

On November 18, the Federal Reserve Board, the FDIC and the OCC proposed clarifications to the revised regulatory capital rules adopted by the agencies in July 2013. The proposal applies to large internationally active...more

Banking Agencies Announce First Outreach Meeting

On November 5, the OCC, FDIC, and the Fed announced that they will hold an outreach meeting on December 2 to review regulations under the Economic Growth and Regulatory Paperwork Reduction Acts of 1996 (EGRPRA)....more

Financial Services Weekly News Roundup - November 2014 #2

The SEC first proposed a study of the fiduciary obligations of brokers and investment advisers as required by the Dodd-Frank Act in July 2010. The SEC still has not made a decision about the shape of a fiduciary rule for...more

Financial Regulatory Developments Focus - November 2014 #2

In this issue: - Bank Prudential Regulation & Regulatory Capital - Compensation - Consumer Protection - Derivatives - Enforcement - Financial Services - Funds -...more

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