Too Big To Fail in the Dodd-Frank Era
Rodge Cohen: Dodd-Frank Fixes "Too Big To Fail"
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
In prepared remarks before the American Council of Life Insurer's Executive Roundtable (Naples, Florida, 9 January 2019), Federal Reserve Board (FRB) Vice Chairman for Supervision Randal Quarles provided the insurance...more
Editor's Note - First Half of 2018 Sees Significant Decline in Publicly Announced or Publicly Filed Enforcement Activity. During the first half of 2018, Enforcement Watch tracked 40 publicly announced or publicly filed...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
Sears marked the end of an era today, as the store that “more than a century ago pioneered the strategy of selling everything to everyone” filed for bankruptcy protection early this morning....more
Marketing Private Life Insurance Separate Accounts to Smaller Banks - Subject to certain exceptions, the so-called “Volcker rule” provisions of the Dodd-Frank Act and regulations thereunder (collectively, the Volcker Rule)...more
On May 24, 2018, President Trump signed the Economic Growth, Regulatory Relief and Consumer Protection Act (the “Reform Act”). The bulk of reform in the Reform Act consists of the elimination of many technical and...more
On May 24, President Trump signed into law the most significant banking legislation since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) in 2010. The bill – named the Economic...more
The US House included the revised Volcker Rule that we’ve discussed in a broader package of Dodd-Frank reforms that it passed with bipartisan support last night. The bill—ostensibly aimed at easing restrictions on small to...more
On March 14, 2018, the U.S. Senate approved the Economic Growth, Regulatory Relief and Consumer Protection Act, a bipartisan bill that would repeal or modify certain provisions of the Dodd-Frank Act and eliminate or ease a...more
On March 21, the House Financial Services Committee approved a proposal to loosen many of the rules implemented as part of the landmark 2010 Dodd-Frank legislation that overhauled the U.S. financial system in the wake of the...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
Mike Crapo, chairman of the US Senate Committee on Banking, Housing, and Urban Affairs, introduced the Economic Growth, Regulatory Relief and Consumer Protection Act which would introduce significant financial regulatory...more
On November 16, Senate Banking Committee (“SBC”) Chairman Mike Crapo (R-ID) introduced S. 2155, the “Economic Growth, Regulatory Relief and Consumer Protection Act,” long-awaited Senate legislation designed to foster economic...more