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And Then There Was One: US FSOC Rescinds AIG’s SIFI Designation

The Financial Stability Oversight Council (FSOC) on September 29, 2017 issued a determination rescinding its prior designation of American International Group, Inc. (AIG) as a systemically important financial institution...more

Federal Reserve Board Announces Proposed Changes to Bank Board Expectations

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

Certain Companies that May be Subject to FDIC Orderly Liquidation Authority under Dodd-Frank are Now Subject to Qualified...

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

Implications of the 2016 Election for Banks, Systemically Important Financial Institutions and Their Investors

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

US Federal Reserve Board Begins the Process of Regulating Insurance Companies

Nearly six years after the adoption of Dodd-Frank’s Title I, which provides for the regulation by the Board of Governors of the Federal Reserve System (Board) of non-bank financial companies – such as insurance companies,...more

MetLife Opinion Turns the Tables on FSOC: Back to the Drawing Board

U.S. District Court Judge Rosemary Collyer recently released her opinion invalidating the decision of the Financial Stability Oversight Council (FSOC or the Council) to designate MetLife a systemically important financial...more

U.S. District Court Overturns FSOC Designation of MetLife as a Systemically Important Financial Institution

On March 29, 2016, MetLife scored a victory as Judge Rosemary Collyer of the U.S. District Court for the District of Columbia invalidated the Financial Stability Oversight Council’s (FSOC) designation of MetLife as a...more

Asset Management Industry: Financial Stability Update, Fall 2015

As U.S. and global regulators continue to evaluate the potential impact, if any, of the asset management industry and its products and activities on financial stability, the regulatory standards that will ultimately be...more

Financial Services Quarterly Report - Second Quarter 2015: U.S. FSOC and Global FSB Signal Continued Scrutiny of Financial...

In recent months, both the U.S. Financial Stability Oversight Council (FSOC or Council) and the international Financial Stability Board (FSB) have taken actions signaling their continued interest in evaluating the potential...more

U.S. FSOC Proposes Qualified Financial Contract Rules and Creates a New Challenge for Large Financial Companies that are not SIFIs

The Financial Stability Oversight Council (Council) proposed regulations (Rule) on January 7, 2015, which create a new challenge for all nonbank financial companies with assets of $50 billion or more. While the four companies...more

FSOC Criticized by Government Accountability Office, but GAO Report Misses Critical Substantive Improvements; FRB Begins to...

The U.S. Government Accountability Office just issued a report on the Financial Stability Oversight Council's (“FSOC”) systemically important financial institution (“SIFI”) designation process, entitled “Further Actions Could...more

U.S. Office of Financial Research Issues Report on Asset Management and Financial Stability

The Office of Financial Research (“OFR”), an office of the U.S. Department of the Treasury, recently issued a report that may provide a roadmap for future designations by the Financial Stability Oversight Council (“FSOC”) of...more

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