Financial Stability Oversight Council

News & Analysis as of

All Financial Regulation in the U.S. Now Subject to Review under February 3, 2017 Executive Order Issued by the President

Seyfarth Synopsis: Hours after the inauguration of President Trump, the White House issued a memorandum which imposed a 90-day delay on regulations which had not yet taken effect. As far as existing financial services law and...more

Extraordinary Opportunity for Bankers to Impact Federal Policy and Regulations

On February 3, 2017, President Trump signed Executive Order 13772 that states his Administration's policy is "to regulate the United States financial system in a manner consistent with the following principles of regulation,...more

President Trump Takes First Steps On Dodd-Frank Reform

Last week, the Trump Administration took initial action toward Dodd-Frank reform. President Trump signed two Presidential actions—one Executive Order regarding the Dodd-Frank Act more broadly, and one Presidential Memorandum...more

President Trump's Financial System Executive Order and What It Means for Dodd-Frank Compliance

On February 3, 2017, President Trump issued an executive order setting out “Core Principles for Regulating the United States Financial System” and requiring review of existing regulations to determine whether they conform to...more

President Trump issues an executive order on core principles for regulating the financial system

On February 3, 2017, the President issued an Executive Order titled “Core Principles for Regulating the United States Financial System.”  The Executive Order is a high-level policy statement consisting of a series of Core...more

Financial Stability Board Issues Activities-Based Recommendations for the Global Asset Management Industry

The FSB continues to plan to revisit whether there are residual entity-specific sources of systemic risk that cannot be addressed effectively by market-wide activities-based policies that would support global systemically...more

Dodd-Frank in a Trump Administration

During the recent campaign, President-elect Donald Trump pledged to repeal the Dodd-Frank Act (DFA) if elected, criticizing the regulatory burdens it imposed and contending that it discouraged lending by banks and impaired...more

US House of Representatives Passes Legislation Eliminating $50 Billion Asset Threshold for SIFI Designation

The US House of Representatives passed a bill (H.R. 6392) that would replace the current supervisory framework under the Dodd-Frank Act that automatically subjects all bank holding companies with $50 billion or more in total...more

Counselor to the US Treasury Secretary, Antonio Weiss, Argues for the Preservation of the FSOC

Antonio Weiss, Counselor to the US Treasury Secretary, argued that the FSOC has become a “critical nerve center during episodes of market volatility or stress,” providing a forum to assess system-wide risks, which was missing...more

Bill Would Limit Applicability of Dodd-Frank Act to Certain Financial Institutions

A bill in Congress would significantly amend the Dodd-Frank Wall Street Reform and Consumer Protection Act (Pub. L. 111–203) to change what institutions might be designated a systemically important risk requiring additional...more

The New Future of US Banking and Financial Services Regulation

The presidential election has opened the possibility of significant changes to the Dodd-Frank Act regime that has been implemented over the last six years. It remains to be seen what plans the incoming administration will...more

What Might Be the Future of the Dodd -Frank Act’s Insurance and Reinsurance- Related Provisions in a Trump Administration?

During the recent election campaign, President-elect Donald Trump pledged to repeal the Dodd-Frank Act if elected, criticizing the regulatory burdens it imposed on different portions of the financial services sector and...more

The Trump Administration: Change By Appointment

The election of Donald J. Trump as the 45th President of the United States, along with the Republican control of the majority of both the House of Representatives and the Senate, will likely result in significant changes in...more

Repeal Dodd-Frank in a Spending Bill?

Something must be afoot inside the Beltway, because Sen. Sherrod Brown (D-OH) and Rep. Maxine Waters (D-CA) sent a letter to Senate and House leaders stating they will oppose ideological policy riders to year-end funding...more

The OCC Rises, the FSOC Dies, and Other Regulatory Predictions

Eight bold regulatory predictions on the direction of U.S. Banking and Fintech regulation in light of the election results. The era of “outside the law” Federal regulation is over. Critics of the CFPB (exclusively...more

An Open Letter to President-Elect Trump: Seven Financial Services Regulation Priorities

Dechert partner Thomas P. Vartanian published an article entitled, "Open Letter to Trump: Weigh the Costs of Regulation," in the November 11 issue of the American Banker. While noting that it is undisputed that federally...more

"Looking Ahead: The U.S. Legal and Regulatory Environment Under a Trump Administration"

Election Day brought an end to a long period of uncertainty that caused market fluctuations and delayed business planning decisions. As we navigate the post-election landscape, many questions remain regarding the potential...more

US Securities and Exchange Commission Proposes Enhanced Regulatory Framework for Covered Clearing Agencies

The US Securities and Exchange Commission voted to establish enhanced standards for the operation and governance of securities clearing agencies that are deemed systemically important by the Financial Stability Oversight...more

Implications of the 2016 Election for Banks, Systemically Important Financial Institutions and Their Investors

Campaign promises rarely turn into specific actions, but when they do, they are necessarily impacted by the dynamics of the legislative process. History suggests, however, that the policies of candidates can be a predictor of...more

Washington Insight - September 2016

House Financial Services Committee Votes To Repeal And Replace Dodd-Frank - On September 13th, the House Financial Services Committee approved the Financial CHOICE Act of 2016 to repeal and replace key parts of the 2010...more

FSOC’s Annual Report Focuses On Cyber Threats And FinTech

In June 2016, the Financial Stability Oversight Council (“FSOC” or the “Council”) released its Annual Report. The Council discussed the continued “pressing concern” of cyber threats and vulnerabilities and also focused on...more

House Financial Services Committee Votes To Repeal And Replace Dodd-Frank

On September 13th, the House Financial Services Committee approved the Financial CHOICE Act of 2016 to repeal and replace key parts of the 2010 Dodd-Frank law by a largely partisan vote of 30 to 26. Democrats declined to...more

Federal Banking Agencies Issue Dodd–Frank Mandated Report on Bank Activities and Investments

On September 8, 2016, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) issued a 107-page joint...more

Orrick's Financial Industry Week in Review

Financial Industry Developments - OCC Discusses Marketplace Lending - On September 13, 2016, Comptroller of the Currency Thomas J. Curry discussed marketplace lending's risks and associated policy questions. He...more

Fed Takes First Steps Toward Setting Capital Requirements for Some Insurers

On June 3, the Federal Reserve Board (the "Fed") released an advance notice of proposed rulemaking (ANPR) and began soliciting comments for the conceptual framework for capital standards that it will use when overseeing the...more

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