After a long lead up, the five agencies (Agencies) with responsibility for the regulations that implement the Volcker Rule (Regulations) have issued a wide ranging proposal to tailor the application of the Regulations in...more
6/15/2018
/ Banking Sector ,
Banks ,
Comment Period ,
Covered Funds ,
Deregulation ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
Financial Institutions ,
Financial Regulatory Reform ,
Hedging ,
Liquidity Risk Management Rule ,
Proposed Amendments ,
Proprietary Trading ,
Public Comment ,
Regulatory Burden ,
Trump Administration ,
U.S. Treasury ,
Volcker Rule
During the Trump Administration’s first year in office, it has implemented major new policy approaches and engaged in significant reversals of Obama Administration policies in many areas. In contrast, the Administration to...more
1/16/2018
/ Asset Management ,
Banks ,
Capital Markets ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Unions ,
Department of Labor (DOL) ,
Dodd-Frank ,
Fiduciary Rule ,
Financial Regulatory Agencies ,
Financial Regulatory Reform ,
Financial Services Industry ,
FSOC ,
Insurance Industry ,
Liquidity ,
Repeal ,
Securities and Exchange Commission (SEC) ,
SIFIs ,
Trump Administration ,
Volcker Rule
After more than two decades in obscurity, the Congressional Review Act (CRA) has now emerged as a major factor in the relationship between the U.S. Congress and the regulatory agencies....more
The Board of Governors of the Federal Reserve (FRB) on August 3, 2017 issued a notice inviting comment regarding Proposed Guidance on Supervisory Expectations for Boards of Directors (Proposal). The Proposal applies to boards...more
9/6/2017
/ Bank Holding Company ,
Banks ,
Board of Directors ,
Directors ,
Federal Reserve ,
Foreign Banks ,
FSB ,
Proposed Guidance ,
Public Comment ,
Savings and Loan Companies ,
SIFIs ,
Supervision
As the general conformance period for banking entities to comply fully with Section 13 of the U.S. Bank Holding Company Act (Volcker Rule) and its implementing regulations (Volcker Regulations) ended on July 21, 2017, two...more
Companies that the Financial Stability Oversight Council (FSOC) believes may be subject to FDIC receivership under the Orderly Liquidation Authority contained in Title II of the Dodd-Frank Act, and certain of their...more
3/8/2017
/ Bank Holding Company ,
Banks ,
Broker-Dealer ,
Court-Appointed Receivers ,
Derivatives Clearing Organizations ,
Dodd-Frank ,
Exemptions ,
FDIC ,
Financial Institutions ,
FSOC ,
Insolvency ,
Investment Adviser ,
Major Swap Participants ,
Qualified Financial Contracts (QFC) ,
recordkeeping ,
Recordkeeping Requirements ,
SIFIs
The Comptroller of the Currency, Thomas Curry, announced on December 2, 2016, that the Office of the Comptroller of the Currency (OCC) intends to move forward with issuing limited purpose national bank charters to financial...more
The presidential election has opened the possibility of significant changes to the Dodd-Frank Act regime that has been implemented over the last six years. It remains to be seen what plans the incoming administration will...more
11/30/2016
/ Banks ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
FDIC ,
Financial Institutions ,
FSOC ,
Glass-Steagall Act ,
Liquidation ,
Presidential Elections ,
Shadow Banking ,
Too Big to Fail ,
Trump Administration ,
Volcker Rule
Campaign promises rarely turn into specific actions, but when they do, they are necessarily impacted by the dynamics of the legislative process. History suggests, however, that the policies of candidates can be a predictor of...more
10/12/2016
/ Acquisitions ,
Banks ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
FSOC ,
Hillary Clinton ,
Industry Consolidation ,
Liquidity ,
Mergers ,
Mortgages ,
OCC ,
Policy Terms ,
Presidential Elections ,
Receivership ,
SIFIs ,
Too Big to Fail ,
Trump Administration ,
Volcker Rule
Under the Volcker Regulations (Regulations), banking entities are sharply restricted in their ability to invest in and sponsor entities that are treated as “covered funds.” During the rulemaking process, the Volcker Agencies...more
As the general July 21, 2015 deadline approached to conform with the implementing regulations (Final Rules) for the Volcker Rule, a key issue remained with respect to the sponsoring, organizing and seeding of investment...more
7/29/2015
/ Banks ,
Covered Funds ,
Final Rules ,
Financial Institutions ,
Foreign Investment ,
Investment Companies ,
Investment Company Act of 1940 ,
Proprietary Trading ,
Public Funds ,
Registered Funds ,
Volcker Rule
The Financial Stability Oversight Council (“FSOC”) has taken the next step in its consideration of the asset management industry, by issuing a notice requesting public comment on whether asset management products and...more
Overall Trends & Outlook -
From an enforcement standpoint, 2013 was another historic year in a number of important ways beyond the sheer number of cases, which were again significant. Federal banking agencies1 issued...more
The Federal Reserve Board (Board) recently adopted final rules representing the most significant change in U.S. regulation of foreign banking organizations (FBOs) since the International Banking Act of 1978. Perhaps most...more
The three U.S. federal banking agencies (the “Agencies”) have adopted a final rule (the “Rule”) that implements the Basel III regulatory capital framework and comprehensively revises the regulatory capital requirements for...more