Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
What Happened? In May 2024, the Financial Stability Oversight Council (FSOC or Council) issued a Report on Nonbank Mortgage Servicing (the Report). The Report recognizes the strengths of nonbank mortgage companies (NMCs) and...more
A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
On November 3, the Financial Stability Oversight Council (FSOC) voted unanimously to finalize the procedures for designating a nonbank financial company for Federal Reserve supervision. FSOC’s Interpretive Guidance aims to...more
In Short - The Situation: The Financial Stability Oversight Council ("FSOC") recently issued a "notification of proposed interpretive guidance" on updated procedures for designating nonbank financial companies as...more
On April 21, 2023, the Financial Stability Oversight Council ("FSOC") issued two important proposals regarding the designation of a nonbank financial firm as a systemically important financial institution ("nonbank SIFI")...more
The Financial Stability Oversight Council (“FSOC”) issued a document on October 21st titled: Report on Climate-Related Financial Risk 2021 (“Report”) The Report was issued in response to the Biden Administration’s Executive...more
On October 21, 2021, the Financial Stability Oversight Council (“FSOC”), established in 2010 by the Dodd-Frank Wall Street Reform and Consumer Protection Act to respond to emerging threats to the stability of the U.S....more
Insurance and Investment Firms Breathe Easier - On December 4, 2019, the Financial Stability Oversight Council adopted final interpretive guidance on addressing systemic threats to the financial system that prioritizes the...more
US lawmakers urge FSOC to designate cloud-based storage systems used by major banks as systemically important financial market utilities. In an August 22, 2019, letter addressed to Treasury Secretary Steven Mnuchin, in his...more
The U.S. Senate on March 14 passed S.2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act), by a vote of 67 to 31. Although the Act would not make the sweeping changes to the Dodd-Frank Act found...more
The U.S. Department of the Treasury (Treasury) recently released its long-awaited review of the determination and designation processes of the Financial Stability Oversight Council (FSOC), created under the Dodd-Frank Wall...more
Director Corday has sent a letter to Keith Noreika, the Acting Comptroller of the Currency, responding to Mr. Noreika’s July 10 letter in which he stated that OCC staff had expressed safety and soundness concerns arising from...more
In a party line vote, the House of Representatives approved the Financial CHOICE Act of 2017. If signed into law, this legislation would profoundly alter the financial services regulatory landscape put in place after the...more
In a Presidential Memorandum, President Trump directed the Secretary of the Treasury, as a member of the Financial Stability Oversight Council, not to cast a nonemergency vote to subject nonbank financial companies to...more
Companies that the Financial Stability Oversight Council (FSOC) believes may be subject to FDIC receivership under the Orderly Liquidation Authority contained in Title II of the Dodd-Frank Act, and certain of their...more
On February 28, 2017, B. Dan Berger, President and Chief Executive Officer of the National Association of Federally-Insured Credit Unions (the “NAFCU“), urged regulatory relief for credit unions in a letter submitted to the...more
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
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
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
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
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
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
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
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