With the hope of finally addressing the uncertainty created by the U.S. Second Circuit Court of Appeal’s holding in Madden v. Midland Funding,1 the Office of the Comptroller of the Currency (OCC) and the Federal Deposit...more
12/19/2019
/ Assignments ,
Consumer Credit Protection ,
FDIC ,
Financial Regulatory Agencies ,
Financial Services Industry ,
Interest Payments ,
Loan Origination Funds ,
Madden v Midland Funding ,
National Bank Act ,
Non-Bank Lenders ,
OCC ,
Partnership Agreements ,
Preemption ,
Proposed Rules ,
Public Comment ,
Usury
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
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