News & Analysis as of

Federal Reserve Global Systemically Important Banks (G-SIBs)

Mayer Brown Free Writings + Perspectives

Cart Before Horse: Banking Regulators Extend Comment Period and Launch Data Collection for Basel Endgame

On October 20, 2023, the US federal banking regulators announced that they were extending the period for public comment to January 16, 2024 for both the (i) Basel Endgame proposal to significantly revise the risk-based...more

Jones Day

Federal Banking Agencies Propose Long-Term Debt Requirements for Large Banks

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In Short: The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more

Davis Wright Tremaine LLP

The Regulatory Trio: Long-Term Debt and Resolution Plan Proposals Signal Need for Greater Clarity and Simplification

On August 29, 2023, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (collectively, FBAs) issued requests for...more

Morrison & Foerster LLP

The Basel III Endgame

On July 27, the three federal banking agencies (the Agencies)[1] jointly proposed changes to the regulatory capital framework applicable to large banks and bank holding companies (the Proposal). The Proposal is the U.S....more

Davis Wright Tremaine LLP

The Revisit: Our Take on the U.S. Banking Agencies' Regulatory Capital Revamp

On July 27, 2023, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, FBAs) issued their long-awaited...more

Latham & Watkins LLP

FRB Vice Chair for Supervision Recommends Stronger Capital Standards for Large US Banks

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After a lengthy “holistic” review and a spring banking crisis, US bank capital requirements finally face overhaul. On July 10, 2023, US Federal Reserve Board (FRB) Vice Chair for Supervision Michael Barr delivered a...more

Cadwalader, Wickersham & Taft LLP

FRB and OCC Release 2023 Stress Test Scenarios

The Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) last week released their 2023 Dodd-Frank Act Stress Test (“DFAST”) scenarios. As noted in the FRB’s release, the “stress tests help...more

Cadwalader, Wickersham & Taft LLP

FRB and FDIC Provide Resolution Plan Feedback to Eight U.S. G-SIBs

Last week, the Federal Reserve Board (“FRB”) and the Federal Deposit Insurance Corporation (“FDIC”) released their feedback to the eight global systemically important banking institutions (“G-SIBs”) headquartered in the...more

Cadwalader, Wickersham & Taft LLP

FRB and FDIC Issue Joint ANPR on Possible Resolution Requirements for Large Banking Organizations While FRB and OCC Approve U.S....

The Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) Board issued an Advanced Notice of Proposed Rulemaking (“ANPR”) titled “Resolution-Related Resource Requirements for Large Banking...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Releases Large Bank Capital Requirements

Last week, the Federal Reserve Board (“FRB”) announced the individual capital requirements for all large banks, effective on October 1. This announcement follows the June announcement on the results of the supervisory stress...more

Nutter McClennen & Fish LLP

Nutter Bank Report, April 2019

FDIC Shares Examiners’ Expectations for Contracts with Technology Service Providers - The FDIC has issued guidance on examiners’ expectations for provisions of contracts between banks and technology service providers...more

Orrick, Herrington & Sutcliffe LLP

An End User’s Practical Guide to the QFC Stay Rules

The Board of Governors of the Federal Reserve System (Board), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) adopted rules (together, the QFC Stay Rules) in 2017...more

A&O Shearman

US Federal Reserve Vice Chairman Randal Quarles Discusses Streamlining the Supervision and Regulation of Large Financial...

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U.S. Board of Governors of the Federal Reserve System Vice Chairman for Supervision, Randal Quarles, discussed the tailoring of supervision and regulation for large financial institutions. Vice Chairman Quarles noted that...more

A&O Shearman

US Federal Reserve Board Approves Final Rule Regarding Single-Counterparty Credit Limits for Bank Holding Companies and Foreign...

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The U.S. Board of Governors of the Federal Reserve System approved a final rule, which implements section 165(e) of the Dodd-Frank Act, and establishes single-counterparty credit limits for bank holding companies and foreign...more

A&O Shearman

Two US Banking Regulators Propose Amendments to Supplementary Leverage Ratio Calculations for GSIBs and Their Insured Depository...

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The U.S. Board of Governors of the Federal Reserve System and U.S. Office of the Comptroller of the Currency published a joint notice of proposed rulemaking and request for comment that would modify the calculation of the...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

OFR Issues Report Challenging Standard for Identifying Systematically Important Banks - On October 26, 2017, the Office of Financial Research ("OFR"), an arm of the Treasury Department, issued a Report of its Director that...more

Proskauer Rose LLP

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

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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

A&O Shearman

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

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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

Morrison & Foerster LLP

A Closer Look at the Final TLAC Rule’s Requirements for IHCs

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On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued final rules requiring global systemically important banks (“G-SIBs”) in the United States, including bank holding...more

A&O Shearman

US Federal Reserve Board Approves Technical Amendments to GSIB Surcharge Rule and Proposes Interim Reporting Rule

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The US Federal Reserve announced the approval of technical amendments to its rule regarding risk-based capital surcharges for US-based global systemically important bank holding companies (GSIB surcharge rule), requiring...more

Morrison & Foerster LLP

TLAC’s Back! Sifting Through the Federal Reserve’s Final TLAC Rule

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On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued its final rules regarding total loss absorbing capacity (the “Final TLAC Rule”) requirements for global systemically...more

Morrison & Foerster LLP

The Fed Revisits CCAR and Proposes CCAR Relief for Large Noncomplex Firms

One of the notable financial regulatory tools that resulted from the post-financial crisis prudential regulations is stress testing. The Board of Governors of the Federal Reserve System (the “Federal Reserve”) has the...more

Dechert LLP

Proposed U.S. Federal Reserve Board Rule’s Impact on Buy-Side Remedies in QFCs with Global Systemically Important Banking...

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The Board of Governors of the U.S. Federal Reserve System (Board) recently proposed a rule (Proposed Rule) that will impact parties to any “qualified financial contract” (QFC), as described below, with a global systemically...more

A&O Shearman

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

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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

Morrison & Foerster LLP

Federal Reserve Proposes Revisions to Form FR Y-7Q to Incorporate Capital Adequacy Standard Reporting Requirements for Foreign...

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

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