News & Analysis as of

Orrick's Financial Industry Week in Review - April 14, 2014

Agencies Apply Increased Leverage Ratio to Large U.S. Banks - On April 8, the Fed, FDIC and OCC adopted the final rule to increase the leverage ratio for the largest U.S. banks. The final rule applies to U.S. bank...more

Regulators Alter Volcker Rule On TruPS CDOs

On January 14, the Federal Reserve Board, the CFTC, the SEC, the OCC, and the FDIC issued an interim final rule to permit banking entities to retain interests in certain collateralized debt obligations backed primarily by...more

Financial Services Bulletin: Action At Federal Agencies

Agencies Approve Interim Final Rules Exempting Certain Interests from the Volcker Rule - On Thursday, January 14, 2013, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation,...more

Observation 1.2 On The Volcker Rule: Foreign Banking Entities – Location, Location, Location

On December 10, 2013, the Board of Governors of the Federal Reserve System (FRB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission (SEC) and...more

Five Federal Agencies Adopt Interim Rule Providing Relief from the Volcker Rule with Respect to Collateralized Debt Obligations...

The Federal Reserve Board, the OCC, the FDIC, the SEC and the CFTC (collectively, the “Agencies”) adopted an interim final rule (the “Interim Rule”) that provides relief from certain requirements of the Volcker rule for...more

Legal Alert: Final Volcker Rule: Update and Key Takeaways for Private Funds

On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Securities and Exchange Commission, and the Commodity Futures...more

Legal Alert: Final Volcker Rule: Update and Key Takeaways for Insurers

On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the Commodity Futures Trading...more

Legal Alert: The Volcker Rule: The Rising Appeal of Registered Investment Companies and BDCs

On December 10, 2013, the U.S. Federal Reserve, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Commodity Futures Trading Commission, and the Securities and Exchange Commission...more

Federal Agencies Issue Statement On Subjecting TruPS CDOs To Volcker Rule

On December 27, in response to substantial criticism and legal action by banking trade groups, the Federal Reserve Board, the OCC, the FDIC, and the SEC stated that they are reviewing whether it is appropriate and consistent...more

Orrick's Derivatives in Review - January 2014

Industry Groups File Lawsuit Challenging Cross-Border Guidance - On December 4, 2013, the Securities Industry and Financial Markets Association, the International Swaps and Derivatives Association, Inc., and the...more

Agencies are Reviewing Treatment of CDOs Backed by Trust Preferred Securities Under the Volcker Rule

On December 27, the Fed, FDIC, OCC and the SEC stated that they are in the process of reviewing whether it would be appropriate to subject collateralized debt obligations backed by trust preferred securities to the Volcker...more

Federal Agencies Reviewing Treatment under Volcker Rule of Collateralized Debt Obligations Backed by TruPS

On December 27, 2013, the FRB, FDIC, OCC and SEC (the “Agencies”) jointly issued a statement which advised financial institutions that the Agencies were reviewing, in response to concerns expressed by community banks and...more

Volcker Rule Promises To Be Godzilla of Bank Regulation

It took almost 3½ years before it finally hatched. And it was big—very big—enormous, in fact. No, it’s not Godzilla. It’s the Volcker Rule. More than two years after the Notice of Proposed Rulemaking, a final rule...more

The Volcker Rule: Impact of the Final Rule on Securitization Investors and Sponsors

On December 10, 2013, the Federal Reserve, FDIC, OCC, SEC and CFTC (the “Agencies”) issued the long-awaited final rule (the “Final Rule”) implementing the Volcker Rule. The Volcker Rule generally prohibits banking entities —...more

Observation 1.1 On The Volcker Rule: Community Banks – Size Does Matter

On December 10, 2013, after more than three years of intensive development, the Board of Governors of the Federal Reserve System (FRB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation...more

Covered Funds Aspects of the Volcker Rule – Frequently Asked Questions

The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the "SEC") issued a final rule, and the Commodity Futures...more

Federal Agencies Finalize Volcker Rule

On December 10, the Federal Reserve Board, the OCC, the FDIC, the SEC, and the CFTC issued a final rule to implement Section 619 of the Dodd-Frank Act, the so-called Volcker Rule. Section 619 was a central component of the...more

Final Rules Issued Implementing the Volcker Rule

On December 10, 2013, five federal agencies — the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange...more

The Volcker Rule: Great Expectations For Regulating Risk

On Tuesday, December 10, five federal regulatory agencies, the Federal Reserve, the Securities and Exchange Commission, the Federal Deposit Insurance Corporation, the Office of the Comptroller and the Commodity Futures...more

Summary of the Volcker Rule

On December 10, 2013, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, and the Commodity...more

The Volcker Rule’s Impact On Banking Entities’ Ownership And Sponsorship Of Structured Finance And Securitization Transactions

On December 10, 2013, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity...more

Orrick's Financial Industry Week in Review - December 16, 2013

Final Rules Implementing the Volcker Rule - On December 10, the Fed, CFTC, FDIC, OCC and SEC issued final rules to implement Section 619 of the Dodd-Frank Act (the Volcker Rule), which prohibit insured depository...more

Federal Agencies Issue Final Volcker Rule

On December 10, 2013, five federal agencies, including the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the...more

Federal Regulatory Agencies Issue Final Rule Implementing Volcker Rule

The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Securities and Exchange Commission jointly adopted and the Commodity Futures Trading Commission...more

The Volcker Rule: Impact of the Final Rule on Foreign Banking Organizations

On December 10, 2013, the Federal Reserve, FDIC, OCC, SEC, and CFTC (the “Agencies”) issued the long-awaited final rule (“Final Rule”) construing the Volcker Rule. The Volcker Rule generally prohibits banking entities — a...more

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