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The Federal Reserve, FDIC and OCC Issue Final Guidance on Risk Management in Third-Party Relationships: Moore & Van Allen

On June 6, 2023, the Board of Governors of the Federal Reserve System (the Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC, and collectively with the...more

Acting Comptroller Hsu Suggests a Potential Path Forward to Address Identified Gaps in the Regulatory Resolution Framework for...

In the fourteen years since the 2008 financial crisis, significant actions have been taken by Federal banking agencies to make the largest financial institutions more resilient and less likely to fail and to require planning...more

Never Waste a Crisis: How Coronavirus May Help Shape the LIBOR Transition

The transition away from LIBOR was born from the financial crisis. For years regulators have been pushing for an alternative to the dominant market benchmark. The underlying market was illiquid. The rate was set by opinion,...more

U.S. Regulator Suggests Easing Post-Crisis Derivatives Rules

In another sign of progress, the Federal Deposit Insurance Corporation (FDIC) proposed easing a rule that requires banks to put cash aside to safeguard derivatives trades among affiliates. The proposal would remove the...more

SEC Staff Issues Statement on Preparing for Impending LIBOR Transition

On July 12, 2019, the U.S. Securities and Exchange Commission (SEC) joined the call to prepare for the transition away from LIBOR. The staff of several Divisions of the SEC (the Divisions of Corporation Finance (DCF),...more

Federal Reserve Vice Chair Urges Companies, Financial Institutions to Begin Shift from LIBOR to Secured Overnight Financing Rate...

Noting that we are at “the start of the next critical stage in the transition away from LIBOR,” Federal Reserve Vice Chair for Supervision Randal K. Quarles delivered taped remarks at the June 3, 2019 Alternative Reference...more

When Someone Shows You Who They Are, Believe Them the First Time: What a Blue Wave in the House Likely Means for Financial...

Elections have consequences and the recent midterm elections are no exception. Having won the House majority, Democrats are expected to proceed with an ambitious agenda in January 2019. Much of the focus has been on how the...more

Transitioning Away from LIBOR: What Is Coming and What Can We Do Now?

The potential transition away from LIBOR has raised significant concerns in the financial markets, including whether LIBOR will end in 2021, what may replace it, what fallback language should be included in contracts in the...more

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