The FRB recently issued an interpretive letter (the “FRB Letter”) in which the FRB granted an individual director (the “Director”) an exemption from the prohibition of the Depository Institution Management Interlocks Act (the...more
The FDIC issued guidance (the “Guidance”; FIL-40-2014) to banks and savings associations that have elected S-corporation tax treatment (collectively, “S-corporation Banks” and each an “S-corporation Bank”) concerning the...more
The FDIC issued a notice of proposed rulemaking (the “Proposed Rule”) that would revise the FDIC’s risk-based deposit insurance assessment system to reflect the final Basel III capital rule (the “Final Capital Rule”) adopted...more
The Federal Financial Institutions Examination Council (the “FFIEC”) announced that it had established a web page on cybersecurity (the “Web Page”), which is designed to serve as a central repository for current and future...more
The FRB, FDIC and OCC (collectively, the “Agencies”) issued a final version of an addendum (the “Addendum”) to their “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure” (the “Policy...more
The FRB, FDIC and OCC (the “Agencies”) published the first of a series of four requests seeking public comments to identify regulations of the respective Agencies that are seen as outdated, unnecessary or unduly burdensome. ...more
The U.S. District Court for the Eastern District of Missouri (the “District Court”) issued a memorandum and order (the “Order”) in which the District Court upheld a decision of the FDIC that contract damages sought by the...more
On April 8, 2014, the FRB, FDIC and OCC (collectively, the “Agencies”) released a final rule (the “Final Rule”) concerning the leverage ratio standards for large, interconnected U.S. banking organizations. The Final Rule...more
On April 2, 2014 the members of the Federal Financial Institutions Examination Council (“FFIEC”) issued two joint statements: the first joint statement regards distributed denial-of-service (“DDoS”) attacks, and the second...more
The OCC, FRB and FDIC (collectively, the “Agencies”) issued joint final guidance (the “Final Guidance”) concerning the Agencies’ key supervisory expectations regarding how medium-sized banking organizations--those with more...more
The Federal Reserve Board, the OCC, the FDIC, the SEC and the CFTC (collectively, the “Agencies”) adopted an interim final rule (the “Interim Rule”) that provides relief from certain requirements of the Volcker rule for...more
1/15/2014
/ Bank Holding Company Act ,
Banks ,
CFTC ,
Collateralized Debt Obligations ,
Compliance ,
Dodd-Frank ,
FDIC ,
OCC ,
Securities and Exchange Commission (SEC) ,
Trust Preferred Securities ,
Volcker Rule
The FDIC’s Division of Risk Management Supervision’s Winter 2013 issue of Supervisory Insights includes an article (the “Article”) that discusses how the banking industry’s asset mix and funding profile have shifted during...more
The FDIC released four new videos (the “Videos,” and each a “Video”) designed to provide technical assistance to directors, officers and employees of depository institutions that are FDIC insured. The Videos are available on...more
1/9/2014
/ Banks ,
Compliance ,
Corporate Officers ,
Debt Restructuring ,
Directors ,
Fair Lending ,
FDIC ,
Leases ,
Municipal Bonds ,
Municipal Securities Issuers ,
Municipal Securities Market
The FRB, the FDIC, and the OCC (the “Agencies”) issued a joint FAQ clarifying certain aspects of the treatment of interests in collateralized debt obligations backed by trust preferred securities (“TruPS CDOs”) under the...more
12/27/2013
/ Banking Sector ,
Collateralized Debt Obligations ,
Dodd-Frank ,
FDIC ,
Financial Regulatory Reform ,
FRB ,
Investment Funds ,
OCC ,
Securities ,
Trust Preferred Securities ,
Volcker Rule
The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Securities and Exchange Commission jointly adopted and the Commodity Futures Trading Commission...more
12/13/2013
/ Banks ,
CFTC ,
Dodd-Frank ,
FDIC ,
Federal Reserve ,
Hedge Funds ,
Market Making ,
OCC ,
Private Equity ,
Proprietary Trading ,
Securities and Exchange Commission (SEC) ,
Volcker Rule
The FDIC, FRB and OCC (the “Agencies”) each made available a regulatory capital estimation tool (the “Estimation Tool”) that is designed to help community banks evaluate the potential impact on their capital ratios of the...more
The OCC, FDIC, and FRB jointly issued final updates to the Interagency Questions and Answers Regarding Community Reinvestment. The final changes (the “Final Q&As”) focus primarily on issues concerning community development...more
The FDIC, the Bank of England, the German Federal Financial Supervisory Authority, and the Swiss Financial Market Supervisory Authority have jointly written to the International Swaps and Derivatives Association (“ISDA”) to...more
The FRB, FDIC, OCC and NCUA (collectively, the “Agencies”) jointly issued guidance to financial institutions entitled InterAgency Supervisory Guidance Addressing Certain Issues Related to Troubled Debt Restructurings (the...more
The FRB, OCC and FDIC (the “Agencies”) jointly issued a notice of proposed rulemaking (the “Proposed Rule”) that would establish a minimum liquidity coverage ratio (the “LCR”) for banking organizations with $250 billion or...more
The FDIC issue a Financial Institution Letter (“FIL-46-2013”) reminding FDIC-insured state nonmember banks (“Banks”) of the importance of developing and implementing a comprehensive asset-liability and interest rate risk...more
The FDIC issued a financial institution letter (“FIL-47-2013”) concerning exclusions from, and limits on indemnification for civil money penalties (“CMPs”) under, banks’ director and officer liability insurance policies ...more
The Board of Directors of the FDIC approved and the FDIC issued a final rule (the “Final Rule”) that excludes deposits in foreign branches of U.S. banks from the guarantee of FDIC insurance under the Federal Deposit Insurance...more
The former Chief Executive Officer and Chairman (the “CEO”) of the failed Summit Bank (the “Bank”), a Washington state-chartered bank with $142.7 million of total assets, entered into a plea agreement (the “Plea Agreement”) ...more
On August 28, 2013, the FDIC, OCC, FRB, SEC, Federal Housing Finance Agency, and Department of Housing and Urban Development (collectively, the “Agencies”) issued a second Notice of Proposed Rulemaking (the “revised...more
9/3/2013
/ Asset-Backed Securities ,
Commercial Loans ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
FDIC ,
FRB ,
OCC ,
Qualified Mortgage Rule ,
Risk Retention ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act