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OCC Proposal and Policy Statement on Bank Mergers Could Freeze the Banking Industry in Place

The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more

What About the Kitchen Sink? FSOC Plans Even More in 2024

In Short - The Situation: Over the course of 2023, the Financial Stability Oversight Council ("FSOC") took steps that increase the risk of nonbank financial companies and financial activities being designated as...more

Federal Banking Agencies Propose Increased Capital Requirements for Large Banks

In Short - The Situation: The federal banking agencies approved a proposal that would implement a "gold-plated" U.S. version of the "Basel III endgame."...more

FSOC Proposals Renew Threat of Nonbank "Systemically Important" Designations

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

White House Instructs Agencies to Analyze and Mitigate "Climate-Related Financial Risk"

Executive Order directs whole-of-government approach and broad regulatory effort. On May 20, 2021, President Biden issued an Executive Order ("Order") directing agencies to analyze and mitigate "climate-related financial...more

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