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Agencies Propose a More Tiered Approach to Large Bank Supervision

On October 31, 2018, the federal banking agencies released two separate proposals that, if adopted, would create a more consistent tiered approach to large bank supervision – in other words, supervision of banking...more

Agencies to Conform HVCRE Exposure Definition to New Law

As reported in a prior Client Alert, new federal legislation enacted into law on May 24, 2018 narrows the types of acquisition, development, and construction (ADC) loans that may be subject to a heightened risk weight under...more

Financial Services Report, Fall 2018

EDITOR’S NOTE - So much for the lazy days of summer. It’s been a busy couple of months on both coasts. In a case of déjà vu all over again, a New York federal court found that the CFPB structure is unconstitutional and that...more

HVCRE Exposures: New Regulatory Guidance

As reported in a prior Client Alert, financial services reforms enacted into law on May 24, 2018, clarified the treatment of acquisition, development, and construction (ADC) loans characterized as high-volatility commercial...more

Agencies Propose Amendment to, and Seek Comment on, Regulations Implementing the Volcker Rule

On May 30, 2018, the Board of Governors of the Federal Reserve System (“Federal Reserve”) issued a proposal (the “Proposed Rule”) to amend the rules implementing Section 13 of the Bank Holding Company Act of 1956 (the...more

HVCRE Clarification Finally Arrives – Congress Passes Legislation Addressing Treatment of ADC Loans under the Capital Rules

On May 22, 2018, Congress passed a financial regulatory reform bill, S. 2155, the “Economic Growth, Regulatory Relief, and Consumer Protection Act” (the “Reform Bill”). Among other things, the Reform Bill clarifies the...more

Financial Regulatory Reform Legislation Proceeds through Congress

On May 22, 2018, the U.S. House of Representatives (“House”) passed S. 2155, the “Economic Growth, Regulatory Relief, and Consumer Protection Act.” The bill was passed on a bipartisan basis with a vote of 258-159. The bill...more

Customer Due Diligence and Beneficial Ownership: Updates to FFIEC Examination Manual and FinCEN Administrative Ruling

May 11, 2018 was the applicability date for FinCEN’s new “Customer Due Diligence Requirements for Financial Institutions” (the “CDD Rule”). FinCEN noted the occasion by issuing a press release to remind covered financial...more

Senate Passes Financial Regulatory Reform Bill

On March 14, 2018, the U.S. Senate passed S. 2155, the “Economic Growth, Regulatory Relief, and Consumer Protection Act.” If enacted into law, S. 2155 would provide modest regulatory relief to regional and community banks,...more

Federal Reserve Board Revises FR Y-7 and Provides Guidance on Enhanced Prudential Standards for Foreign Banking Organizations

On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more

Financial Services Report – Winter 2017

EDITOR’S NOTE - The holidays came early for the financial services industry. First, the Senate voted to repeal the CFPB’s rule banning class waivers in arbitration agreements in consumer financial contracts. Then,...more

House Passes Bill Addressing Industry Concerns Regarding the Capital Treatment of High Volatility Commercial Real Estate (HVCRE)...

On November 7, 2017, the House of Representatives, by voice vote, passed H.R. 2148, the Clarifying Commercial Real Estate Loans Act (the “Bill”). The Bill was reported favorably out of the House Financial Services Committee...more

Federal Banking Agencies Propose New Approach to Capital Treatment for Acquisition, Development, and Construction Loans

On September 27, 2017, the three federal banking agencies (the “Agencies”) released a Notice of Proposed Rulemaking (“NPR”), which proposes changes to certain aspects of the bank capital rules under the “standardized...more

OCC Seeks Public Comment on the Volcker Rule

Section 13 of the Bank Holding Company Act (the “Volcker Rule”) and its implementing regulations (the “Implementing Regulations”) generally prohibit banking entities from engaging in proprietary trading and from investing in,...more

Federal Banking Agencies Announce No-action Position on Certain Foreign Excluded Funds Under the Volcker Rule

Section 13 of the Bank Holding Company Act of 1956, as amended, and its implementing regulations (the “Volcker Rule”) generally prohibit a “banking entity” from engaging in proprietary trading and from investing in,...more

U.S. House of Representatives Passes the Financial CHOICE Act of 2017

On June 8, 2017, the Financial CHOICE Act of 2017 (the “CHOICE Act”) was passed on a party line vote by the U.S. House of Representatives, with nearly all Republicans voting in support and nearly all Democrats voting against...more

House Financial Services Committee Holds Hearing on the Financial CHOICE Act of 2017

On April 26, 2017, the Financial Services Committee of the U.S. House of Representatives held a hearing entitled "A Legislative Proposal to Create Hope and Opportunity for Investors, Consumers, and Entrepreneurs." The purpose...more

The SEC Issues a Request for Comment on Possible Changes to Industry Guide 3

On March 1st, 2017, the Securities and Exchange Commission (“Commission”) issued a request for comment (“RFC”) seeking comment on Industry Guide 3, “Statistical Disclosure by Bank Holding Companies” (“Guide 3”). Guide 3,...more

Federal Reserve Board Announces Procedures to Request an Extended Transition Period to Conform Illiquid Funds to the Volcker Rule

On December 9, 2016, the Board of Governors of the Federal Reserve System (“Federal Reserve Board”) issued SR 16-18, “Procedures for a Banking Entity to Request an Extended Transition Period for Illiquid Funds” (“SR 1618”). A...more

Federal Reserve Officially Extends Volcker Rule Conformance Period with Respect to “Legacy Covered Funds” to July 21, 2017

The Board of Governors of the Federal Reserve System (“Federal Reserve”), consistent with its previously announced intention, extended the conformance period with respect to investments in and relationships with covered funds...more

Federal Reserve Proposes Revisions to Form FR Y-7Q to Incorporate Capital Adequacy Standard Reporting Requirements for Foreign...

On Monday, April 4, 2016, the Board of Governors of the Federal Reserve System (“Federal Reserve”) proposed a revision to Form FR Y-7Q to incorporate the capital adequacy standard reporting requirements for foreign banking...more

Agencies Issue Guidance on Capital Deduction Requirement under the Volcker Rule for Investments in Collateralized Debt Obligations...

On Friday, March 4, 2016, the Volcker Inter-Agency Group posted a new frequently asked question (FAQ 21), clarifying the capital deduction requirement under the Volcker Rule for investments in Qualifying TruPS CDOs. FAQ 21...more

Narrowing of Licensing Exemption Under California Finance Lenders Law for Consumer Lenders and Brokers

The California Department of Business Oversight (the “CDBO”) has issued a new regulation that will eliminate a statutory licensing exemption under the California Finance Lenders Law (the “CFLL”) for nonbank operating...more

Volcker Rule: Federal Agencies Issue New Guidance Regarding the Seeding Period Treatment for Registered Investment Companies...

Under guidance issued on July 16, 2015 by the federal agencies responsible for implementing the Volcker Rule (the “Agencies”) RICs and FPFs need not be treated as banking entities during a seeding period of up to three...more

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