Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
The Financial Stability Oversight Council unanimously approved an analytic framework for financial stability risk identification, assessment and response and interpretive guidance on nonbank financial company determinations...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
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
The National Association of Insurance Commissioners (NAIC) held its 2019 Spring National Meeting from April 5 through 9 in Orlando, Florida. This meeting was distinguished by a very large class of new commissioners (15 in...more
The Financial Stability Oversight Council Improvement Act of 2019 (the “Act”) was recently introduced in the United States Senate. Under existing law, the Financial Stability Oversight Council (“FSOC”) can subject certain...more
The Financial Stability Oversight Council (“FSOC”) announced on October 17, 2018 that it has voted unanimously to rescind the designation of Prudential Financial Inc. (“Prudential”) as a systemically important financial...more
The Federal Reserve bank released the minutes from its September meeting yesterday. Among other things, we learned that the Fed Governors moved largely in lockstep on September’s rate hike, even as the crew was less unanimous...more
The Financial Stability Oversight Council (FSOC) voted unanimously to remove Prudential from its list of non-bank systemically important financial institutions (SIFIs)....more
A look at Amazon’s newest concept—Amazon Go—a convenience store that opens in Seattle today complete with “shelves of food” found at other stores (including Whole Foods) but with nary a cashier in sight....more
During the Trump Administration’s first year in office, it has implemented major new policy approaches and engaged in significant reversals of Obama Administration policies in many areas. In contrast, the Administration to...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
The U.S. Department of the Treasury (Treasury) recently released a report examining the regulatory framework for the asset management and insurance industries (Report). The Report is the third in a series of four reports that...more
As retailers do all they can to fight the e-commerce wave, some bricks-and-mortar shops are experimenting with a rather counterintuitive strategy: smaller spaces and a showroom-style approach....more
The Financial Stability Oversight Council (FSOC) on September 29, 2017 issued a determination rescinding its prior designation of American International Group, Inc. (AIG) as a systemically important financial institution...more
Uber’s got more than a spot of bother on its hands in London after this morning’s announcement that the company’s largest market in Europe won’t renew the ride-hailing service’s license to operate in the city (citing “a lack...more
Editor's Note - State Regulators Sue OCC Over Federal FinTech Charter. On April 26, the Conference of State Bank Supervisors (CSBS) sued the Office of the Comptroller of the Currency (OCC) in the U.S. District Court for...more
The new administration is working on a tax plan that would slash corporate tax rates to 15 percent and doing so with a hastiness that could jeopardize House Republicans’ ability to make the cuts permanent....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
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 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
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
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
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
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