On January 29, 2024, the OCC issued a proposed policy statement[1] describing the general principles it uses to evaluate applications for approval of transactions under the Bank Merger Act (“BMA”), principally bank mergers,...more
On July 27, the three federal banking agencies (the Agencies)[1] jointly proposed changes to the regulatory capital framework applicable to large banks and bank holding companies (the Proposal). The Proposal is the U.S....more
On April 28, 2023, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the United States Government Accountability Office (GAO), and the New York Department of...more
UPDATE (3/20 PM):
Developments Related to Flagstar Bank, SVBB, SVB Financial Group, Credit Suisse, and First Republic Bank-
On March 19, 2023, the FDIC announced that the agency has entered into a purchase and...more
3/22/2023
/ Banks ,
Borrowers ,
Deposit Accounts ,
FDIC ,
Federal Reserve ,
Investors ,
Liquidity ,
Receivership ,
Swiss Banks ,
Systemic Risk Buffer ,
U.S. Treasury
UPDATE (3/12 PM):
U.S. Treasury Uses Systemic Risk Exception to Protect Depositors of Failed Banks and the Federal Reserve Board Establishes New Emergency Facility.
Following the failure of Silicon Valley Bank (SVB) on...more
3/13/2023
/ Bank Deposits ,
Board of Governors ,
FDIA ,
FDIC ,
Federal Reserve ,
Line of Credit ,
Loans ,
Popular ,
Receivership ,
U.S. Treasury ,
Uninsured Deposits ,
Wages
Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more
7/15/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Arbitration ,
Auto-Dialed Calls ,
BSA/AML ,
CARES Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
CRA ,
Dodd-Frank ,
E-SIGN ,
Fair Lending ,
FASB ,
FDIC ,
Federal Reserve ,
FinCEN ,
FinTech ,
HMDA ,
Interim Final Rules (IFR) ,
Money Market Mutual Fund Liquidity Facility (MMLF) ,
OCC ,
Paycheck Protection Program Lending Facility (PPPLF) ,
Popular ,
Remittance Transfer Rule ,
Request For Information ,
RESPA ,
SPVs ,
TCPA ,
Volcker Rule
On June 25, 2020, five federal agencies (the “Agencies”) finalized amendments to the rules implementing section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) related to the prohibition on investing,...more
7/1/2020
/ ABS ,
Bank Holding Company Act ,
Banks ,
Covered Funds ,
FDIC ,
Federal Reserve ,
Final Rules ,
Foreign Investment ,
OCC ,
SBIC ,
Securities and Exchange Commission (SEC) ,
Venture Capital ,
Volcker Rule
On April 30, 2020, the Board of Governors of the Federal Reserve System (“FRB”) announced an expansion of the Main Street Lending Program (“MSLP”) and clarified certain aspects of the program through publication of a list of...more
On January 30, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) approved a final rule (the “Final Rule”) revising the regulations related to the determination of “control” of banks under the...more
On April 23, 2019, the Board of Governors of the Federal Reserve System (“Federal Reserve”) released a proposed rule (“Proposed Rule”) to revise regulations related to the determination of “control” under the Bank Holding...more
The Federal Reserve and the FDIC published proposed changes to resolution plan (or “living will”) requirements applicable to U.S. and foreign banking organizations. The regulatory changes are necessary because the 2018...more
On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more
On December 9, 2016, the Board of Governors of the Federal Reserve System (“Federal Reserve Board”) issued SR 16-18, “Procedures for a Banking Entity to Request an Extended Transition Period for Illiquid Funds” (“SR 1618”). A...more
EDITOR’S NOTE -
Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more
12/7/2016
/ Arbitration ,
Article III ,
Blockchain ,
CalOPPA ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Card Surcharges ,
Cybersecurity ,
Data Breach ,
Distributed Denial of Service ,
ECOA ,
FDCPA ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
FinTech ,
HMDA ,
HUD ,
LGBTQ ,
Military Lending Act ,
NYDFS ,
OCC ,
OIG ,
Prepaid Payment Products ,
Risk Management ,
SCRA ,
Spokeo v Robins ,
Truth in Lending Act (TILA)
The Board of Governors of the Federal Reserve System (“Federal Reserve”), consistent with its previously announced intention, extended the conformance period with respect to investments in and relationships with covered funds...more
BELTWAY -
Every Last Penny Counts -
Five federal banking agencies issued a Supervisory Bulletin titled “Interagency Guidance Regarding Deposit Reconciliation Practices” (the “Guidance”). The Guidance outlines...more
6/8/2016
/ Arbitration ,
Article III ,
CID ,
Civil Investigation Demand ,
Class Action Arbitration Waivers ,
Comptroller ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Customer Due Diligence (CDD) ,
Data Privacy ,
Data Security ,
Debt Collection ,
ECOA ,
FDCPA ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
FFIEC ,
FHFA ,
Financial Institutions ,
FinCEN ,
FinTech ,
Hawkins v Community Bank of Raymore ,
Mobile Banking ,
Net Stable Funding Ratio (NSFR) ,
Online Marketplace Lending ,
Payday Loans ,
Payment Protection Insurance ,
PCI-DSS Standard ,
Preemption ,
RESPA ,
SCOTUS ,
Spokeo v Robins ,
Standing ,
Student Loans ,
TCPA ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Truth in Lending Act (TILA) ,
UDAAP ,
Virtual Currency ,
Volcker Rule
On Monday, April 4, 2016, the Board of Governors of the Federal Reserve System (“Federal Reserve”) proposed a revision to Form FR Y-7Q to incorporate the capital adequacy standard reporting requirements for foreign banking...more
Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more
8/6/2015
/ Accredited Investors ,
AIF ,
Alternative Investment Fund Managers Directive (AIFMD) ,
Bank Recovery and Resolution Directive (BRRD) ,
Capital Rules ,
CFTC ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Covered Banking Entity ,
Covered Funds ,
Credit Cards ,
Cross-Border Transactions ,
Debt Collection ,
Derivatives ,
Dodd-Frank ,
ECOA ,
EMIR ,
EU ,
European Securities and Markets Authority (ESMA) ,
Executive Compensation ,
Exemptions ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDCPA ,
FDIC ,
Federal Reserve ,
Fiduciary Duty ,
Final Rules ,
Financial Regulatory Reform ,
Financial Transaction Tax ,
Foreign Banks ,
FSOC ,
HMDA ,
HOEPA ,
Incentive Compensation ,
Investment Company Act of 1940 ,
IOSCO ,
Liquidity Risk Management Rule ,
MiFID II ,
Mortgage Servicing Rules ,
NRSRO ,
OCC ,
Privacy Notice Rule ,
Proprietary Trading ,
Prudential Standards ,
Remittance Transfer Rule ,
Reporting Requirements ,
Risk Management ,
Security-Based Swaps ,
Shadow Banking ,
SIFIs ,
Stand-Alone SBSDs ,
Swap Execution Facilities ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Transparency ,
Truth in Lending Act (TILA) ,
UCITS ,
UDAAP ,
Volcker Rule
On June 26, 2014, the Federal Reserve Board (“Board”) published on its website responses to frequently asked questions (“FAQs”) relating to enhanced prudential standards under Section 165 of the Dodd-Frank Act and its...more
Last week, the Federal Reserve Board (the “Board”) issued its long-awaited final enhanced prudential rule (Regulation YY) under Section 165 of the Dodd-Frank Act (the “Final Rule”) for bank holding companies and foreign...more
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
12/12/2013
/ CFTC ,
Exemptions ,
Extraterritoriality Rules ,
FDIC ,
Federal Reserve ,
Foreign Banks ,
OCC ,
Proprietary Trading ,
Securities and Exchange Commission (SEC) ,
Sovereign Debt ,
Volcker Rule
In a move that will be welcomed by the U.S. foreign bank community and its clients, the Federal Reserve Board yesterday issued an interim final rule that accords foreign banks’ uninsured U.S. branches and agencies parity with...more