Risk-Based Approaches

News & Analysis as of

Supervisory or Enforcement Action? Deputy Director Explains How the CFPB Decides

In his prepared remarks for an appearance last month at the Exchequer Club, Consumer Financial Protection Bureau Deputy Director Steven Antonakes discussed the CFPB’s risk-based approach to supervision. (The Exchequer Club’s...more

Opt-Out Election for AOCI Under Basel III Approaches

The beginning of 2015 marked the implementation of Basel III for community banks including the changes to required capital ratios. Although community banks have been preparing for the implementation for months, one of the...more

Consultation Paper On A Riskbased Capital Framework For The Insurance Industry In Hong Kong

On 16 September 2014, the Office of the Commissioner of Insurance ("OCI") announced the publication by the Insurance Authority ("IA") of a "Consultation Paper on a Risk-based Capital Framework for the Insurance Industry in...more

Federal Reserve Board Releases a Proposed Rule to Impose Risk-Based Capital Surcharges on GSIB U.S. Bank Holding Companies

On December 9, the Federal Reserve Board (the “Board”) released a proposed rule (the “Proposed Rule”) to establish risk-based capital surcharges for U.S. bank holding companies identified as “global systemically important...more

Bank Regulator Eyes Insurer Capital

The Federal Reserve Board (FRB) has begun a process that will lead to the imposition of new capital requirements on some large insurance companies. Pursuant to Section 171 of the Dodd-Frank Act, the FRB gained authority to...more

Connecticut Department of Energy and Environmental Protection Releases "Evaluation of Risk-Based Decision Making" With Public...

On August 29, 2014, the Connecticut Department of Energy and Environmental Protection (DEEP) released “Evaluation of Risk-based Decision Making,” a report prepared by CDM Smith under contract to the state. DEEP has now...more

OCC Publishes Final Rule that Revises the Risk-Based Capital Definition of Eligible Guarantee for Advanced Approaches Banks

The OCC, the Fed, and the FDIC have published a final rule that revises the advanced approaches risk-based capital rules by removing the requirement that only guarantees provided by certain counterparties are eligible for...more

FTC Settles First FCRA Risk-Based Pricing Notice Enforcement Action

The Federal Trade Commission recently announced the settlement of its first enforcement action for alleged violations of the Fair Credit Reporting Act (FCRA) risk-based pricing rule (Rule). The settlement demonstrates that...more

Viewing complaints on the CFPB website: should a company register?

Should our company sign up to use an online company portal to view consumer complaints about us submitted to the CFPB? That’s the question we are being asked by clients who have been contacted by a CFPB representative...more

Capital Is Contagious— The FDIC and OCC Approve Final Risk-based Capital Rules, and the Agencies Propose a Supplemental Leverage...

Today, July 9, the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”) took two significant actions on the implementation of new regulatory capital requirements in the U.S....more

"Anti-Corruption Due Diligence in Corporate Transactions: Implementing a Risk-Based Approach"

Anti-corruption issues continue to present significant risks in acquisition and investment transactions because regulators continue robust enforcement in this area and emerging markets often present the greatest economic...more

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