Do Banks Still Need Holding Companies?
On July 30, the FDIC released an NPRM to regulate parent companies of industrial banks and industrial loan companies (the industrial entities). The proposed rule would revise the definition of “Covered Company” to include...more
The Federal Reserve Board recently updated sections of the Bank Holding Company Supervision Manual. (Changes to the manual were last made in November 2021.) The manual provides guidance for conducting inspections of bank...more
Court Rules that Debt Collector Violated FDCPA with Communication to Dunning Vendor - A federal appellate court has recently ruled that a debt collector violated certain privacy requirements under the federal Fair Debt...more
The Board of Governors of the Federal Reserve System (the Board) issued a much-anticipated final rule (Final Rule) on January 30 to amend and codify—in certain respects, for the first time—its framework for making...more
On January 30, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) approved a final rule (the “Final Rule”) revising the regulations related to the determination of “control” of banks under the...more
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
In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more
The Federal Reserve Board (Board) has adopted a rule that is intended to provide more detailed, accessible and slightly more generous criteria and procedures for use in determining whether control exists within the meaning of...more
Seeking to increase the transparency of the rules for determining control of a banking organization, the Federal Reserve Board of Governors (Board) asked for public comment on a new proposal....more
The Federal Reserve Board has issued a notice of proposed rulemaking proposing revisions to Regulations Y and Regulations LL. The proposal would revise and clarify the standards for determining when a company exercises...more
As of the end of August 2018, two key provisions of The Economic Growth, Regulatory Relief, and Consumer Protection Act (aka the Crapo bill, S.2155, or increasingly, EGRRCPA) have become effective: the increase in the small...more
Some bankers view the rapid rise of “fintech” as an existential threat to traditional banks, especially community banks. But while fintech surely is changing financial services, it is also creating new opportunities for...more
The US federal banking agencies with responsibility for enforcing the Volcker Rule have issued temporary one year no-action relief with respect to certain private non-US investment funds that are not “covered funds” for...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
The Staff of the SEC Division of Trading and Markets, Investment Management, and Corporate Finance provided updated guidance on June 12, 2015 in response to frequently asked questions (“FAQs”) regarding the SEC’s final rule...more
In the wake of the post-2008 “Great Recession,” many financial institutions were left holding an odoriferous bag of non-performing loans and bank-owned real estate (“REO Property”) resulting from foreclosures on collateral....more
The SEC has issued a series of FAQs on its final rule implementing section 13 of the Bank Holding Company Act of 1956 (“BHC Act”), commonly referred to as the “Volcker Rule.”...more