Do Banks Still Need Holding Companies?
On August 15, the Fed released an enforcement action against a registered bank holding company and its parent company alleging financial and governance concerns. The agreement established concrete steps and regulatory...more
On March 30, the U.S. Treasury Department’s Office of Foreign Assets (OFAC) announced a $30 million settlement with a national bank to resolve potential civil liabilities stemming from trade insourcing software that the bank...more
The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (Federal Banking Agencies) on December 27, 2019 provided temporary relief from...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
On February 5, the Federal Reserve Board and Office of Comptroller of Currency released the stress scenarios for the 2019 stress test cycle for domestic bank holding companies and foreign bank intermediate bank holding...more
The U.S. Financial Stability Oversight Council issued a proposed decision with respect to a national bank’s petition to not treat the surviving entity of a bank holding company parent merging into its large U.S. national bank...more
On February 2, 2018, the Fed announced that it issued a consent Cease and Desist order with Wells Fargo—the bank holding company. The Fed’s press release noted that Wells is replacing 4 directors within this year (out of 17...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
On August 9, 2017, the Board of Governors of the Federal Reserve (the "Federal Reserve") published proposed guidance on certain supervisory expectations for Boards of Directors of banks and holding companies. The proposal...more
The Small Bank Holding Company ("BHC") Policy Statement ("Policy Statement") was adopted by the Federal Reserve in 1980 to facilitate transfers of small banking organizations, including BHCs formed to assume individuals' bank...more
On March 4, 2016, the Board of Governors of the Federal Reserve System (the “Fed”) issued a Notice of Proposed Rulemaking (“NPRM”), inviting comment on reproposed rules (the “Reproposed Rules”) that would establish single...more
Why it matters - Deals with favored investors have fallen out of favor with the Federal Reserve Board of Governors, as evidenced by a new memorandum from the regulator. SR 15-15, issued on December 3, 2015, cautions...more
The Nutter Bank Report is a monthly publication of the firm's Banking and Financial Services Group. Headlines - 1. Interagency Guidance Recommends Banks Review CRE Risk Management Strategies 2. Federal Reserve...more
1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more
The Federal Reserve Board on July 20 approved a final rule requiring the largest, most systemically important US bank holding companies to further strengthen their capital positions. Under the rule, a firm that is identified...more
When the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “Board”) and the Federal Deposit Insurance Corporation (the “FDIC”) finalized the Liquidity Coverage...more
On April 9, the Board of Governors of the Federal Reserve (Board) issued a final rule to expand the applicability of its Small Bank Holding Company Policy Statement and also apply it to certain savings and loan holding...more
On April 9, 2015, the Federal Reserve Board issued a final rule to implement statutory changes to the Small Bank Holding Company Policy Statement (Small BHC Policy Statement) which will: (1) increase the asset threshold of...more
On January 29, the Board of Governors of the Federal Reserve System (Board) invited public comment on a proposed rule to expand the applicability of the Board’s Small Bank Holding Company Policy Statement (Policy Statement)...more
On January 29, Federal Reserve Board (Fed) invited public comment on a proposed rule to expand the applicability of the Board’s Small Bank Holding Company Policy Statement (Policy Statement) for small bank holding companies...more
The Enhanced Prudential Standards (Regulation YY) of the Board of Governors of the Federal Reserve System represent a significant shift in the U.S. regulation of foreign banking organizations (FBOs). In general, Regulation...more
Overview This Client Alert continues Pepper’s observations on the Volcker Rule. Critical attention should be paid to the Volcker Rule’s anti-evasion provision, a powerful tool granted by Congress to the regulatory agencies to...more
The Board of Governors of the Federal Reserve System (the Board) recently issued an order granting the second of three statutorily permitted one-year extensions for compliance by banking entities with the requirements of the...more
On December 11, Congress passed legislation redefining the size of smaller institutions allowed to take advantage of the Federal Reserve’s Small Bank Holding Company Policy Statement from less than $500 million to less than...more
On December 9, the Federal Reserve Board (the “Board”) released a proposed rule (the “Proposed Rule”) to establish risk-based capital surcharges for U.S. bank holding companies identified as “global systemically important...more