News & Analysis as of

Federal Reserve Foreign Banks

Fed Adopts Final Rule Regarding Contract Termination Provisions for Repos, Stock Loans and Swaps with Systemically Important Banks

by Proskauer Rose LLP on

On September 1, 2017 the Federal Reserve voted to adopt a final rule requiring U.S. global systemically important banking institutions ("GSIBs") and the U.S. operations of foreign GSIBs to amend qualified financial contracts...more

Federal Reserve Board Announces Proposed Changes to Bank Board Expectations

by Dechert LLP on

The Board of Governors of the Federal Reserve (FRB) on August 3, 2017 issued a notice inviting comment regarding Proposed Guidance on Supervisory Expectations for Boards of Directors (Proposal). The Proposal applies to boards...more

Two Volcker Rule Updates: Foreign Excluded Funds and Seed Investments

by Latham & Watkins LLP on

Two recent developments involving the Volcker Rule have significant implications for financial regulation in both the US and internationally. Update 1: Temporary Relief for Certain Foreign Funds - On July 21, 2017, the...more

US Agencies Complete Resolution Plan Evaluation of 16 Domestic Firms and Provide Resolution Plan Guidance to Four Foreign Banks

by Shearman & Sterling LLP on

The US FDIC and the Federal Reserve Board completed their evaluation of the 2015 resolution plans of 16 domestic banks and separately issued guidance to four foreign banks....more

Orrick's Financial Industry Week In Review

Financial Industry Developments - Class Action Against Lending Club and WebBank Headed to Defeat - On Monday, January 31, 2017, a federal district court in the Southern District of New York granted a motion to...more

US Federal Reserve Board Finalizes Revisions to Form FR Y-7 Filed by Foreign Banking Organizations

by Shearman & Sterling LLP on

The US Federal Reserve Board published a notice in the Federal Register that it has finalized its proposed revisions to Form FR Y-7Q implementing the home country capital adequacy requirements prescribed in Sections...more

US Board of Governors of the Federal Reserve System and US Federal Deposit Insurance Corporation Permit Reduced Resolution Plan...

by Shearman & Sterling LLP on

The Federal Reserve Board and the FDIC announced that they are permitting certain foreign banking organizations with limited US operations to file “reduced content” resolution plans for their next three resolution plans...more

US Board of Governors of the Federal Reserve System Issues Guidance for Assessing Risk Management at Institutions with Less Than...

by Shearman & Sterling LLP on

The Federal Reserve Board issued supervisory guidance for supervised institutions with total consolidated assets of less than $50 billion for assessing risk management. The guidance notes that sound risk management principles...more

US Board of Governors of the Federal Reserve System and US Federal Deposit Insurance Corporation Grant Extension to Four Foreign...

by Shearman & Sterling LLP on

The Federal Reserve Board and the FDIC announced that they are giving four foreign banking organizations a one-year extension for the submission of their next US resolution plans. Barclays PLC, Credit Suisse Group, Deutsche...more

US Board of Governors of the Federal Reserve System Finalizes Regulatory Reporting Requirements for Intermediate Holding Companies...

by Shearman & Sterling LLP on

The US Board of Governors of the Federal Reserve System adopted a proposal to extend various regulatory reporting requirements to US intermediate holding company (IHC) subsidiaries of foreign banking organizations...more

Federal Reserve Updates Risk Management Supervisory Guidance for Smaller FBOs

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

Banking Agencies Permit “Reduced Content” Living Wills for Smaller FBOs

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

US Federal Reserve Board Proposes Rule on Close-Out of Qualified Financial Contracts Involving Large, Complex Financial Firms

by Shearman & Sterling LLP on

The US Federal Reserve Board proposed a rule to support US financial stability by enhancing the resolvability of large, complex financial firms. The proposed rule would require US global systemically important banking...more

US Board of Governors of the Federal Reserve System Proposes New Data Items for Regulatory Reporting by Foreign Banking...

by Shearman & Sterling LLP on

The US Board of Governors of the Federal Reserve System proposed changes to various reporting forms, including FR Y-7N, FR Y-7NS and FR Y-7Q, requiring collection of fourteen new data items to monitor compliance with enhanced...more

FRB Requests Comments on Proposed Single-Counterparty Credit Limits

The Board of Governors of the Federal Reserve System ("FRB") has requested comments on reissued proposed rules that would establish a single-counterparty credit limits ("SCCL") for domestic and foreign bank holding companies...more

Another Brick in the Wall: The Fed Reproposes Single-Counterparty Credit Limits for Large Banking Organizations

by Morrison & Foerster LLP on

On March 4, 2016, the Board of Governors of the Federal Reserve System (the “Fed”) issued a Notice of Proposed Rulemaking (“NPRM”), inviting comment on reproposed rules (the “Reproposed Rules”) that would establish single...more

Observation 3.0: Frequently Asked Questions and Answers on the Volcker Rule and the Implications for Foreign Banks Investing in...

by Pepper Hamilton LLP on

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

Dodd-Frank at 4: Where do we go from here?

by Morrison & Foerster LLP on

Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more

Financial Regulatory Developments Focus - June 2015 #3

by Shearman & Sterling LLP on

In This Issue: - US Financial Stability Oversight Council Releases Guidance Regarding Calculations of Stage 1 Threshold - US Federal Agencies Issue Final Standards for Assessing Diversity Policies and Practices of...more

Orrick's Financial Industry Week in Review

SEC Provides Additional Analysis Related to Proposed Pay Ratio Disclosure Rules - On June 4, the Securities and Exchange Commission provided additional analysis related to its proposed rules for pay ratio disclosure. The...more

Federal Reserve Board Proposes to Include Legal Entity Identifiers in Certain Banking Organization Reporting

by White & Case LLP on

One difficulty encountered by national banking authorities during the course of the 2008 global financial crisis was identifying the ultimate parent for the trades made by various subsidiaries of dealers. To assist in...more

Financial Services Weekly News Roundup - March 2015

by Goodwin on

Federal Regulators Address the Scope of the Marketing Restriction in the Volcker Rule SOTUS Exemption. The federal regulatory agencies responsible for implementing the Volcker rule—The Federal Reserve Board, the...more

Federal Agencies Release New Volcker Rule Guidance for Non-U.S. Banking Entities and Fund Sponsors Seeking to Rely on the “SOTUS”...

by Ropes & Gray LLP on

On February 27, 2015, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange...more

"New Provisions Require Structural Change for Foreign Banking Organizations"

The Enhanced Prudential Standards (Regulation YY) of the Board of Governors of the Federal Reserve System represent a significant shift in the U.S. regulation of foreign banking organizations (FBOs). In general, Regulation...more

Federal Reserve Issues Second Extension of Volcker Compliance Date, Previews Final Extension Next Year

by Ballard Spahr LLP on

The Board of Governors of the Federal Reserve System (the Board) recently issued an order granting the second of three statutorily permitted one-year extensions for compliance by banking entities with the requirements of the...more

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