The Office of the Comptroller of the Currency published an interpretive letter on September 21, 2020 (Letter), confirming that national banks and federal savings associations (together, banks) may hold “stablecoin” reserves...more
Several federal agencies have announced various measures to help the United States respond to the economic dislocations from the COVID-19 coronavirus pandemic. This Dechert OnPoint summarizes several significant initiatives...more
3/31/2020
/ Banks ,
Capital Requirements ,
CARES Act ,
Coronavirus/COVID-19 ,
Economic Injury Disaster Loans ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Agencies ,
Liquidity ,
Money Market Funds ,
Mortgage-Backed Securities ,
OCC ,
Primary Dealer Credit Facility (PDCF) ,
Relief Measures ,
SBA ,
Term Asset-Backed Securities Loan Facility (TALF)
The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (Federal Banking Agencies) on December 27, 2019 provided temporary relief from...more
2/10/2020
/ Bank Holding Company ,
Banks ,
Board of Directors ,
Compliance ,
Credit Extension ,
FDIC ,
Federal Bank Regulatory Agencies ,
Federal Reserve ,
Fund Management Companies ,
Insider Information ,
Investment Adviser ,
Investment Funds ,
Loans ,
OCC ,
Portfolio Companies ,
Regulation O ,
Relief Measures ,
Voting Shares
The Federal Reserve Board (FRB) recently issued a proposed rule that would codify and clarify when a company is presumed to have a controlling influence over the management and policies of a second company (Proposed...more
7/3/2019
/ Asset Management ,
Bank Holding Company Act ,
Banks ,
Board of Directors ,
CBCA ,
Controlling Influence Test ,
Controlling Stockholders ,
Federal Reserve ,
HOLA ,
Investment Funds ,
Investors ,
Non-Controlling Interests ,
Private Equity ,
Proposed Amendments ,
Proxy Contests ,
Public Comment ,
Voting Control Test ,
Voting Shares
After a long lead up, the five agencies (Agencies) with responsibility for the regulations that implement the Volcker Rule (Regulations) have issued a wide ranging proposal to tailor the application of the Regulations in...more
6/15/2018
/ Banking Sector ,
Banks ,
Comment Period ,
Covered Funds ,
Deregulation ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
Financial Institutions ,
Financial Regulatory Reform ,
Hedging ,
Liquidity Risk Management Rule ,
Proposed Amendments ,
Proprietary Trading ,
Public Comment ,
Regulatory Burden ,
Trump Administration ,
U.S. Treasury ,
Volcker Rule
During the Trump Administration’s first year in office, it has implemented major new policy approaches and engaged in significant reversals of Obama Administration policies in many areas. In contrast, the Administration to...more
1/16/2018
/ Asset Management ,
Banks ,
Capital Markets ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Unions ,
Department of Labor (DOL) ,
Dodd-Frank ,
Fiduciary Rule ,
Financial Regulatory Agencies ,
Financial Regulatory Reform ,
Financial Services Industry ,
FSOC ,
Insurance Industry ,
Liquidity ,
Repeal ,
Securities and Exchange Commission (SEC) ,
SIFIs ,
Trump Administration ,
Volcker Rule
As the general conformance period for banking entities to comply fully with Section 13 of the U.S. Bank Holding Company Act (Volcker Rule) and its implementing regulations (Volcker Regulations) ended on July 21, 2017, two...more
Under the Volcker Regulations (Regulations), banking entities are sharply restricted in their ability to invest in and sponsor entities that are treated as “covered funds.” During the rulemaking process, the Volcker Agencies...more
As the general July 21, 2015 deadline approached to conform with the implementing regulations (Final Rules) for the Volcker Rule, a key issue remained with respect to the sponsoring, organizing and seeding of investment...more
7/29/2015
/ Banks ,
Covered Funds ,
Final Rules ,
Financial Institutions ,
Foreign Investment ,
Investment Companies ,
Investment Company Act of 1940 ,
Proprietary Trading ,
Public Funds ,
Registered Funds ,
Volcker Rule
The Federal Reserve Board (Board) recently adopted final rules representing the most significant change in U.S. regulation of foreign banking organizations (FBOs) since the International Banking Act of 1978. Perhaps most...more