The OCC issued final guidelines (the “Final Guidelines”) that call for strengthened governance and risk management practices at the following categories of large financial institutions with $50 billion or more in average...more
In a speech presented to the Practicing Law Institute’s Private Equity Forum on June 30, 2014, Norm Champ, Director of the SEC’s Division of Investment Management (the “Division”), discussed the rise of open-end mutual funds...more
On April 10, 2014, Comptroller of the Currency Thomas J. Curry presented remarks concerning risk management and related corporate governance issues before the American Bankers Association Risk Management Forum. Comptroller...more
The OCC issued proposed guidelines (the “Proposed Guidelines”) that would establish minimum standards for the design and implementation of a risk governance framework (the “Risk Framework”) by national banks, federal savings...more
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 SEC issued Release No. 34-71194 (the “Adopting Release”) adopting amendments under the Securities Exchange Act of 1934 (the “Exchange Act”) that remove references to credit ratings by ratings agencies (including...more
On December 11, 2013, the Federal Financial Institutions Examination Council (the “FFIEC”), on behalf of its members (the OCC, FRB, FDIC, NCUA and the Consumer Financial Protection Bureau (“CFPB”)), released final guidance...more
The FRB issued guidance on managing outsourcing risks (the “Guidance”), intended to highlight the potential risks arising from the use of third-party service providers, describe the components of an appropriate service...more
The Financial Stability Board (the “FSB”), a group of representatives from central banks, finance ministries and financial supervisors from the Group of 20 leading economies, Hong Kong, the Netherlands, Singapore, Spain and...more
The OCC issued updated and comprehensive guidance (OCC Bulletin 2013-29, the “Guidance”) to national banks and federal savings associations (collectively, “Banks”) concerning assessment and management of risks associated with...more
The CFTC approved final rules requiring enhanced protections afforded customers and customer funds held by futures commission merchants (“FCMs”). The rules require FCMs to adopt and enforce a risk management program,...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
Comptroller of the Currency, Thomas J. Curry, made a speech at the Exchequer Club in Washington, D.C. on September 18, 2013 in which he discussed the increasing risks to banks and the financial system from the growing...more