Too Big to Fail

News & Analysis as of

Banks May Be Required to Increase Reserves

The Federal Reserve is expected to require the biggest U.S. banks to increase reserves in an effort to prevent the possibility of another financial crisis. Federal Reserve Governor Daniel K. Tarullo is scheduled to testify...more

Former Analyst Claims Moody’s Falsely Inflated Ratings

Former Moody’s analyst, Ilya Kolchinsky, has accused the credit rating powerhouse of overstating its ratings for countless toxic mortgage-backed securities that caused the financial meltdown in 2008, misleading investors and...more

Banking & Financial Services E-Note - July 2014

In This Issue: - New Rule Will Require Banks to Provision for Bad Loans Earlier - Four Years After Dodd-Frank, Law Still Unfinished - Senate Panel to Review Borrowing of 'Too Big to Fail' Banks - Community...more

SEC “Fearful” of Wall Street Banks

Following the financial crisis, the U.S. Securities and Exchange Commission has received sharp criticism from the public for its seemingly weak enforcement of Wall Street’s too big to fail banks. Surprisingly, this sentiment...more

FRB Governor Tarullo Outlines Top Regulatory Priorities for 2014

In testimony before the Senate Banking Committee on February 6, FRB Governor Daniel Tarullo set forth the FRB’s top regulatory priorities for 2014. While Governor Tarullo noted the recent progress in implementing the...more

FDIC Board Releases Single Point of Entry Resolution Strategy for Public Comment

On December 18, 2013, the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) published a widely anticipated notice in the Federal Register (the “Notice”) setting forth the FDIC’s single point of entry...more

SEC Enforcement/Securities Litigation and D&O Insurance

Recent SEC Enforcement Developments - .. Change in SEC policy regarding “no admissions” settlements - SEC Chair Mary Jo White has joined with colleagues at DOJ to change the perception that U.S. companies are...more

Insurance Regulatory Update - Holding Company Supervision, Designation of Prudential Financial as Being "Too Big to Fail,"...

The National Association of Insurance Commissioners ("NAIC") 2013 Summer National Meeting, which was held in late August, saw a continuation of the debate over major insurance regulatory reforms. The first of these reforms...more

Banking & Financial Services E-Note: August 29, 2013

In This Issue: - World Leaders to Crack Down on Shadow Banking Industry - Obama Urges Lawmakers to Get Busy Finishing Dodd-Frank Rules - CFPB, RICO Pressure Big Banks to Rein in Credit Card Debt - States...more

Federal Reserve Board Issues Final Large Bank Assessment Rule

On August 16, the Federal Reserve Board issued a final rule establishing the process by which it will assess annual fees for its supervision and regulation of large financial companies. The Dodd-Frank Act directed the Board...more

Despite the Best of Intentions, Paving the Way for the Next Financial Meltdown

At the Cannes Summit in November 2011, the G-20 Leaders endorsed the Key Attributes of Effective Resolution Regimes for Financial Institutions (‘the Key Attributes’) as the international standard for resolution regimes. As...more

Barofsky and Bair on Banks and Bailouts*

As the United States continues to pull itself out of the credit crisis, these two books shed light on the Washington infighting behind the government's response to the crisis and, more broadly, the shape of financial...more

Financial Stability Board Designates Nine Global Insurance Groups as "Global Systemically Important Insurers"

The Financial Stability Board (FSB), tasked by the G-20 to prevent a future financial crisis, on July 18, 2013, designated nine large insurance groups as Global Systemically Important Insurers (G-SIIs), three from the United...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

Spitzer "Disappointed" in Wall Street's Regulators [Video]

June 19 (Bloomberg Law) -- Eliot Spitzer, former Governor and Attorney General for the State of New York, talks with Bloomberg Law's Lee Pacchia about the so-called revolving door between the public and private spheres. While...more

Financial Services Legislative and Regulatory Update -- June 10‚ 2013

In This Issue: Leading the Past Week; Legislative Branch; Executive Branch; International; and Upcoming Hearings. Excerpt from Leading the Past Week - And the beat goes on… Another week with the White...more

Credit Crunch Digest -- May 2013

This issue of the Credit Crunch Digest focuses on recent developments in alleged Libor rate manipulation litigation; settlements in two mortgage-backed securities lawsuits; potential actions by state attorney generals...more

Too Big To Fail in the Dodd-Frank Era  [Video]

May 31 (Bloomberg) -- Davis Polk Partner Randall Guynn speaks with Bloomberg Law's Lee Pacchia about how Dodd-Frank's orderly liquidation authority (OLA) gives lawmakers better choices when faced with the failure of complex...more

Too Early to Tell If Dodd-Frank Ends “Too Big To Fail”

The debate regarding “too big to fail” (“TBTF”) has reemerged as a focus of regulators, legislators, and the media. We review the regulatory activity since the Dodd-Frank Act was enacted and show that new proposals intended...more

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