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Vice Chair Barr Speaks on Liquidity Risk Management and Preparation for Use of Discount Window

Last Friday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the ECB Forum on Banking Supervision in Frankfurt, Germany entitled The Importance of Effective Liquidity Risk...more

FRB, FDIC, OCC and NCUA Testify at Congressional Oversight Hearings

This week, the Senate Banking Committee and the House Financial Services Committee held oversight hearings with leaders of the Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”), the National Credit...more

A Further Look at the FRB’s Debit Interchange Cap Proposal

As we mentioned last week, the Federal Reserve Board (“FRB”) announced proposed changes to Regulation II (Debit Card Interchange Fees and Routing), which is the implementing regulation of the Durbin Amendment to the...more

Federal Banking Agencies Finalize Community Reinvestment Act Rules

On Tuesday, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a final rule to amend and update...more

FRB Governor Bowman Speaks on Financial Stability

Last week, Federal Reserve Board (“FRB”) Governor Michelle Bowman gave a speech entitled Financial Stability in Uncertain Times, focusing on the “financial stability risks and vulnerabilities” she is most focused on....more

Vice Chair Barr Speaks on Capital Endgame Proposal

On Monday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the American Bankers Association Annual Convention entitled Capital Supports Lending regarding the Basel III...more

Financial Kaleidoscope October 2023 - Fed Issues FAQs Clarifying That Credit-Linked Notes Can Serve as Valid Capital Relief Tools...

On September 28, the Federal Reserve Board (“FRB”) posted three new FAQs to its website regarding Regulation Q (Capital Adequacy of Bank Holding Companies, Savings and Loan Holding Companies, and State Member Banks). The FAQ...more

Fed Issues FAQs Clarifying That Credit-Linked Notes Can Serve as Valid Capital Relief Tools for U.S. Banks

On September 28, the Federal Reserve Board (“FRB”) posted three new FAQs to its website regarding Regulation Q (Capital Adequacy of Bank Holding Companies, Savings and Loan Holding Companies, and State Member Banks). The FAQ...more

Industry Trades Really Don’t Like the Basel III Endgame Proposal

As we covered previously, on July 27, 2023, the U.S. prudential bank regulators (the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”)...more

The Three Federal Banking Agencies Propose Long-Term Debt Requirement for All Large Banking Organizations

The Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a proposed rule (the “LTD NPR”) to require large banks...more

Capital Idea? Risk-Based Capital, Capital Relief Trades and the Proposed Basel III Endgame Capital Rules

On July 27, 2023, the U.S. federal prudential bank regulators (the Federal Deposit Insurance Corporation, the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency) proposed new capital requirements...more

Banking Agencies Finalize Interagency Policy Statement on CRE Loan Workouts

On June 30, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Office of the Comptroller of the Currency (“OCC”) and the National Credit Union Administration (“NCUA”) finalized their Policy...more

Agencies Issue Proposed Interagency Guidance on Real Estate Appraisal Reconsiderations of Value

Last week, the Office of the Comptroller of the Currency (“OCC”), Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”), and the Consumer Financial...more

Banking Agencies Finalize Interagency Guidance on Third-Party Risk Management

On June 6, the three Federal bank regulatory agencies (the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)), issued final interagency...more

FRB, FDIC and GAO Release Reports Reviewing Supervision of Silicon Valley Bank and Signature Bank

Last Friday, the Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) released reports evaluating their supervision of the failed Silicon Valley Bank (“SVB”) and Signature Bank (“Signature”),...more

OCC and FDIC Provide Supervisory Guidance on Certain Overdraft Practices

The Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the “Agencies”) provided supervisory guidance this week on certain overdraft practices. Of particular...more

Congressional Hearings Calling Federal Regulators to Task for Recent Bank Failures

Both the Senate Banking Committee and House Financial Services Committee held hearings this week on the federal regulatory response to the failures of Silicon Valley Bank (“SVB”) and Signature Bank. Witnesses at both hearings...more

FRB Establishes Bank Term Funding Program to Aid Liquidity Availability

As we noted very briefly on Monday in our “Quick Take on a Sudden Change in the Banking Landscape,” among the various actions the government took Sunday evening to try to stabilize the banking market, the Federal Reserve...more

FRB Governor Bowman Speaks on Bank Regulation and Supervision

Federal Reserve Board (“FRB”) Governor Michelle Bowman gave remarks last week to the American Bankers Association (“ABA”) Community Banking Conference. Governor Bowman discussed the role of FRB independence, predictability...more

Banking Agencies Issue Joint Statement on Crypto-related Liquidity Risks

Earlier yesterday, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”) issued a “Joint Statement on Liquidity Risks to Banking Organizations...more

FRB and OCC Release 2023 Stress Test Scenarios

The Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) last week released their 2023 Dodd-Frank Act Stress Test (“DFAST”) scenarios. As noted in the FRB’s release, the “stress tests help...more

Vice Chair Brainard Resigns from Fed to Head Up NEC

Federal Reserve Board (“FRB”) Vice Chair Lael Brainard submitted her resignation from the FRB earlier this week, effective on or about February 20. Vice Chair Brainard is resigning from the FRB to become President Biden’s...more

Vice Chair Barr Speaks on Financial Inclusion

Federal Reserve Board (“FRB”) Vice Chair of Supervision Michael Barr gave remarks to the Banking on Financial Inclusion Conference at Jackson State University early this week....more

FRB Issues Policy Statement on Permissible Activities of State Member Banks While Denying Uninsured Crypto-focused Bank’s...

The Federal Reserve Board (“FRB” or “Board”) issued two seemingly related press releases late last week. The first announced the denial of the Federal Reserve membership application by Custodia Bank, a Wyoming special purpose...more

Federal Reserve Announces Pilot Climate Scenario Analysis Exercise Details

Last week, the Federal Reserve Board (FRB) announced additional details on its pilot climate scenario analysis (CSA) involving six of the largest U.S. banks. The additional details include a Participant Instructions Document...more

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