The Consumer Financial Protection Bureau (the “CFPB”) has published a final rule implementing the requirements of Section 1071 of the Dodd-Frank Act (the “Final Rule”), which mandated data collection on certain credit...more
4/19/2023
/ Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Dodd-Frank ,
ECOA ,
Enforcement ,
Final Rules ,
Financial Institutions ,
LGBTQ ,
Minority-Owned Businesses ,
Small Business ,
Small Business Loans ,
Women-Owned Businesses
The Federal Reserve Board (“FRB”) rarely issues denials for applicants to become members of the Federal Reserve System. Senator Elizabeth Warren has even criticized the FRB for their number of approvals – although in the...more
On July 29, 2021, the Alternative Reference Rates Committee (“ARRC”) of the Federal Reserve formally announced and recommended1 CME Group’s forwardlooking Term Secured Overnight Financing Rate (“Term SOFR”) rates.2 Important...more
This is an update to a previous post. This update highlights the formal endorsement of Term SOFR by the ARRC, expands the discussion to include Ameribor and dives more deeply into the issues associated with Term SOFR swaps...more
8/4/2021
/ Alternative Reference Rates Committee (ARRC) ,
Bank Loan Markets ,
Broker-Dealer ,
CFTC ,
Compliance ,
End-Users ,
Federal Reserve ,
Financial Institutions ,
Fixed-Rate Loans ,
Interest Rates ,
Lenders ,
Libor ,
Liquidity ,
Secured Overnight Funding Rate (SOFR)
Last month marks the tenth anniversary of the United Nations’ Human Rights Council adoption of the Guiding Principles on Business and Human Rights (“UNGPs”), setting forth the internationally-accepted framework for the role...more
In a press release on June 8th, the Commodity Futures Trading Commission (the “CFTC”) published its first release in a series called the “SOFR First Transition Initiative” as a best practice. One goal for this sort of “best...more
6/10/2021
/ Best Practices ,
Broker-Dealer ,
CFTC ,
Compliance ,
Dealers ,
Financial Institutions ,
Over The Counter Derivatives (OTC) ,
Regulatory Oversight ,
Secured Overnight Funding Rate (SOFR) ,
SEFs ,
Swap Dealers