While the Trump Administration’s approach to bank regulation has been the subject of much speculation, specific proposals have yet to emerge, and the administration has yet to name key personnel in the regulatory agencies. ...more
A federal court has rejected an attempt by former First Republic Bank employees to recover assets held in a rabbi trust that funded deferred compensation benefits. In Harrington v. Federal Deposit Insurance Corporation, the...more
A federal court has rejected an attempt by former First Republic Bank employees to recover assets held in a rabbi trust that funded deferred compensation benefits. In Harrington v. Federal Deposit Insurance Corporation, the...more
The Office of the Comptroller of the Currency (the “OCC”) recently issued the agency’s semi-annual perspective on key risks facing banks in 2024 with a special focus on potential threats to safety and soundness. The OCC...more
A federal district judge in Texas has enjoined federal bank regulators from enforcing the recently overhauled Community Reinvestment Act (“CRA”) rules. The injunction was issued on the eve of the first effective date under...more
Operational resilience is the ability of a bank to prepare for, adapt to, and withstand or recover from disruptions. These disruptions flow from external events such as natural disasters, malicious actors, pandemics, or...more
The last two years have seen a significant uptick in the number of transactions involving credit union acquisitions of banks with 26 deals announced and two transactions already announced in 2024. Yet, the law around these...more
The New York Department of Financial Services (“NYDFS”) has released a comprehensive revision of the cybersecurity requirements for state-regulated financial services firms, including banks and insurance companies. The new...more
The Federal Deposit Insurance Corporation (the “FDIC”) has proposed formal corporate governance and risk management standards for banks with assets of $10 billion or more that are subject to FDIC supervision. The detailed...more
The Federal Reserve Board (“FRB”) Inspector General (the “OIG”) has issued a highly critical report regarding FRB supervision of Silicon Valley Bank (“SVB”) in the years preceding the bank’s failure in March 2023. The...more
A recent survey of bank executives reported that cloud computing was a top-five spending priority and eight out of ten respondents indicated that at least twenty percent of their operations would be in the cloud by the end of...more
A periodic review of regulatory enforcement actions is a useful guide to what not to do in the financial services sector. This post focuses on several recent enforcement actions – one by the Federal Reserve Board (the...more
The Senate Banking, Housing, and Urban Affairs Committee approved legislation on June 21, 2023 with bipartisan support that would provide federal bank regulators with enhanced powers to hold senior executives directly...more
A toxic combination of poor risk management and poor regulatory supervision proved fatal for Silicon Valley Bank (“SVB”) and Signature Bank (“Signature”), according to a series of reports released on April 28, 2023 by federal...more