On June 6, 2024 federal regulators published a final rule addressing Quality Control Standards for Automated Valuation Models. This was a collaborative rulemaking effort that included regulators from the Office of the...more
On September 18, 2023, the U.S. Basel III Endgame proposal was published in the Federal Register. The comment period ended on January 16, 2024, with the banking regulators (the Federal Reserve, the OCC, and the FDIC) having...more
We have previously written about the possible economic and litigation implications of mushrooming corporate debt. Now, the Federal Reserve has flagged some of those same concerns....more
The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity Futures Trading...more
The Situation: The Federal Reserve, Office of the Comptroller of the Currency ("OCC"), Federal Deposit Insurance Corporation ("FDIC"), Securities and Exchange Commission ("SEC"), and Commodity Futures Trading Commission...more
On Thursday, June 25, 2020, 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...more
The federal agencies responsible for the Volcker Rule have proposed to clarify some requirements for exclusion from the definition of “covered fund” and to increase the types of funds excluded from that definition. The...more
Last week 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 Futures...more
On January 30, 2020, the U.S. Securities and Exchange Commission (SEC), the Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (“Fed”), the Federal Deposit...more
The US and China have scheduled two more rounds of high-level trade talks with hopes for an agreement between the economic superpowers by late April, even as China has begun to push back against some of the US’s major...more
In 2013, the Obama administration issued the Cole Memorandum, which called a truce between federal prosecutors and marijuana businesses operating legitimately under state law. After regime change in Washington, however, it...more
You can never go wrong starting off a commentary with a butchered bit from the Bard, right? “Now is the winter of our discontent” spake Richard III, an unamiable leader perhaps reminding us all today of our unamiable...more
SEC Approves Rules to Ease Investor Access to Exhibits in Company Filings - On March 1, 2017, the Securities and Exchange Commission (SEC) voted to adopt rule and form amendments that will require issuers to include a...more
Financial Industry Developments - Prohibition on Dealing or Investing in Industrial or Commercial Metals - On January 3, 2017, the Office of the Comptroller of the Currency (the "OCC") finalized a rule that...more
On October 22, 2014, 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, the Federal Housing...more
Federal Reserve, OCC, FCA, FHFA and FDIC Adopt Joint Final Rule on Swap Margin Requirements - On October 22, the Office of the Comptroller of the Currency (the "OCC"), the Federal Reserve Board (the "Board"), the Farm...more
Effective December 24, 2015, all securitizations of residential mortgage loans (RMBS), both public and private, will be subject to the Credit Risk Retention Rule (the “Rule”).[1] The Rule was promulgated on December 24, 2014,...more
After three years of waiting, we now have our Risk Retention Rule. All six of the Agencies responsible for the Rule – the FDIC, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the...more
CLO managers and lead arrangers of syndicated loans received special attention in a proposal jointly released by six federal agencies to implement the credit risk retention requirements of Section 941 of the Dodd-Frank Act....more