On Thursday, April 9, the Federal Reserve Board (“FRB”) announced the terms sheets of four new liquidity facilities and expanded the scope of the previously announced Term Asset-backed Securities Liquidity (“TALF”), the...more
On March 31, the Federal Reserve Board (“FRB”) announced the establishment of a temporary repurchase agreement facility for foreign and international monetary authorities, known as the “FIMA Repo Facility.” This is the...more
To mitigate the “severe disruptions” to the U.S. economy caused by the COVID-19 crisis, the Federal Reserve Board (“Federal Reserve”) is ramping up its efforts to “support…the flow of credit to American families and...more
The Federal Reserve is establishing a Money Market Mutual Fund Liquidity Facility (“MMFL Facility”) for prime money market mutual funds to support “the flow of credit to households and business” in these current markets. ...more
I. INTRODUCTION -
As a result of the recent outbreak of COVID-19, financial markets and institutions have experienced significant disruptions. ...more
On November 6, 2019, the Securities and Exchange Commission (“SEC”) voted 3-2 to issue two notices of proposed rulemaking (“NPR”) amending the requirements to submit and resubmit shareholder proposals, and modifying the rules...more
On Wednesday, September 25th, the House of Representatives approved the “Secure and Fair Enforcement (SAFE) Banking Act of 2019” (H.R. 1595) by a vote of 321 to 103. The bipartisan bill is the first stand-alone cannabis...more
The plan would tax all capital gains as ordinary income; end deferral of capital gains tax for the wealthy -
Senate Finance Committee Ranking Member Ron Wyden (D-OR) recently released a proposal, “Treat Wealth Like Wages,”...more
Our original political update was going to be more general in nature covering the turbulent state of British politics and the UK Prime Minister's "Do or Die" determination to leave the EU on 31 October with or without a deal....more
On May 14, 2019, the Board of Governors of the Federal Reserve System (the “Board”) issued a notice of proposed rulemaking to revise the Board’s regulations on determining controlling influence over a company for purposes of...more
Sen. Tammy Baldwin (D-WI) and Rep. Bill Pascrell (D-NJ) recently reintroduced the “Carried Interest Fairness Act of 2019” (the “Act”). The sponsors claim that the Act would “provide for the proper tax treatment of personal...more
On October 23, the Department of Labor (“DOL”) published a proposed rule intended to make it easier for small businesses to join together to offer employee retirement benefits through defined-contribution Association...more
On September 15, 2008, Lehman Brothers declared bankruptcy, an event considered by many to mark the beginning of the credit crisis of 2008–2009 and the unprecedented public policy responses that followed. Much has been...more
Recent activity in Congress suggests that the return from the July 4th recess will see a continued push to reform the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Dodd-Frank”) before year’s end. This...more
Forty-six states currently have marijuana legalization laws. Twenty-nine states and the District of Columbia have legalized medical marijuana, while seventeen states have allowed access to certain strains for some medical...more
The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) has been an agency under fire. Acting Director Mick Mulvaney has begun to institute significant changes at the Bureau. And last year, a panel of the D.C. Circuit...more
2/13/2018
/ Administrative Proceedings ,
Article II ,
Constitutional Challenges ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Kickbacks ,
Mortgages ,
PHH Corp. v CFPB ,
Popular ,
Reinsurance ,
Removal For-Cause ,
RESPA ,
Single Director
On January 16, 2018, Federal Housing Finance Agency (“FHFA”) Director Melvin L. Watt sent a document to Senate Banking Committee Chairman Mike Crapo (R-ID) and Ranking Member Sherrod Brown (D-OH) that describes the FHFA’s...more
Housing finance reform, one of the elusive, last remaining to-do items on the post-Great Recession list, may finally be addressed during the first half of 2018. Over the last few years, Congress has been setting the stage...more
Early 2018 will likely see the most significant progress on reforming the Dodd-Frank Act (“DFA”) since its passage in 2010 thanks to four key efforts: the Financial CHOICE Act and activity in the House Financial Services...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
On October 26, 2017, the U.S. Department of the Treasury (the “Treasury”) released a report entitled “A Financial System That Creates Economic Opportunities: Asset Management and Insurance,” the third in a series of reports...more
On June 8, the House passed H.R. 10, the “Financial CHOICE Act” (“FCA”), by a party-line vote of 233-186. The votes in opposition to the FCA consisted of all Democrats and one Republican, while only Republicans voted in...more
On April 19, 2017, House Financial Services Committee (“HFSC”) Chairman Jeb Hensarling (R-TX) released an updated version of the Financial CHOICE Act (“FCA 2.0”), a discussion draft that would reform the Dodd–Frank Wall...more
The European Commission’s action plan builds on the results of its green paper on retail financial services published for public consultation in December 2015.
In the framework of the Capital Markets Union (CMU)...more
On March 2, 2017, the Department of Labor’s (“DOL”) proposal to delay its change to the definition of the term “fiduciary” (the “Fiduciary Rule”) was published in the Federal Register. Against expectations, the proposed delay...more