Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more
7/15/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Arbitration ,
Auto-Dialed Calls ,
BSA/AML ,
CARES Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
CRA ,
Dodd-Frank ,
E-SIGN ,
Fair Lending ,
FASB ,
FDIC ,
Federal Reserve ,
FinCEN ,
FinTech ,
HMDA ,
Interim Final Rules (IFR) ,
Money Market Mutual Fund Liquidity Facility (MMLF) ,
OCC ,
Paycheck Protection Program Lending Facility (PPPLF) ,
Popular ,
Remittance Transfer Rule ,
Request For Information ,
RESPA ,
SPVs ,
TCPA ,
Volcker Rule
On June 25, 2020, five federal agencies (the “Agencies”) finalized amendments to the rules implementing section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) related to the prohibition on investing,...more
7/1/2020
/ ABS ,
Bank Holding Company Act ,
Banks ,
Covered Funds ,
FDIC ,
Federal Reserve ,
Final Rules ,
Foreign Investment ,
OCC ,
SBIC ,
Securities and Exchange Commission (SEC) ,
Venture Capital ,
Volcker Rule
On January 30, 2020, five federal agencies (the “Agencies”) proposed amendments to the rules implementing section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) related to the prohibition on investing,...more
On August 20, 2019, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) approved a final rule (the “2019 Final Rule”) to amend the rules implementing Section 13 of the Bank...more
On August 20, 2019, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) approved a final rule (the “2019 Final Rule”) to amend the rules implementing Section 13 of the...more
On July 22, 2019, five federal agencies (the “Agencies”) published a final rule (the “Final Rule”), which conforms the regulations implementing the Volcker Rule to statutory modifications provided by Sections 203 and 204 of...more
On December 18, 2018, five federal agencies (the “Agencies”) released a proposed rule (“Proposed Rule”) to conform the regulations implementing the Volcker Rule to statutory modifications provided by Sections 203 and 204 of...more
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
9/12/2018
/ Arbitration ,
BSA/AML ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Financial Services Industry ,
FinTech ,
Fixing America’s Surface Transportation Act (FAST Act) ,
Mortgages ,
OCC ,
RMBS ,
TCPA ,
U.S. Treasury ,
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
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
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
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
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
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
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
Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more
8/6/2015
/ Accredited Investors ,
AIF ,
Alternative Investment Fund Managers Directive (AIFMD) ,
Bank Recovery and Resolution Directive (BRRD) ,
Capital Rules ,
CFTC ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Covered Banking Entity ,
Covered Funds ,
Credit Cards ,
Cross-Border Transactions ,
Debt Collection ,
Derivatives ,
Dodd-Frank ,
ECOA ,
EMIR ,
EU ,
European Securities and Markets Authority (ESMA) ,
Executive Compensation ,
Exemptions ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
FDCPA ,
FDIC ,
Federal Reserve ,
Fiduciary Duty ,
Final Rules ,
Financial Regulatory Reform ,
Financial Transaction Tax ,
Foreign Banks ,
FSOC ,
HMDA ,
HOEPA ,
Incentive Compensation ,
Investment Company Act of 1940 ,
IOSCO ,
Liquidity Risk Management Rule ,
MiFID II ,
Mortgage Servicing Rules ,
NRSRO ,
OCC ,
Privacy Notice Rule ,
Proprietary Trading ,
Prudential Standards ,
Remittance Transfer Rule ,
Reporting Requirements ,
Risk Management ,
Security-Based Swaps ,
Shadow Banking ,
SIFIs ,
Stand-Alone SBSDs ,
Swap Execution Facilities ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Transparency ,
Truth in Lending Act (TILA) ,
UCITS ,
UDAAP ,
Volcker Rule
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
On Friday, February 27, 2015, the Volcker Inter-Agency Group posted a new frequently asked question (FAQ 13), clarifying the scope of the so-called “marketing restriction” under the SOTUS covered fund exemption. The SOTUS...more
Final regulations under the section of the Dodd-Frank Act known as the “Volcker Rule” were enacted in December 2013 (the “Final Rule”) by five federal financial regulatory agencies (collectively, the “Agencies”). The Volcker...more
On December 10, 2013, the Federal Reserve, FDIC, OCC, SEC, and CFTC (the “Agencies”) issued the long-awaited final rule (“Final Rule”) construing the Volcker Rule. The Volcker Rule generally prohibits banking entities — a...more
12/12/2013
/ CFTC ,
Exemptions ,
Extraterritoriality Rules ,
FDIC ,
Federal Reserve ,
Foreign Banks ,
OCC ,
Proprietary Trading ,
Securities and Exchange Commission (SEC) ,
Sovereign Debt ,
Volcker Rule
Table of Contents:
Introduction; Financial Stability Reform; Resolution Planning; Agencies and Agency Oversight Reform; Securitization Reform; Derivatives Regulation; Investor Protection Reform; Credit Rating Agency...more
12/29/2012
/ Capital Requirements ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Governance ,
Credit Ratings ,
Derivatives ,
Disclosure Requirements ,
Dodd-Frank ,
Financial Stability Acts ,
Foreign Banks ,
Mortgage Loan Originators ,
Mortgages ,
Securitization ,
Servicing Policies ,
Volcker Rule