Do Banks Still Need Holding Companies?
A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more
On June 23, the Federal Reserve Board issued the aggregate and individual results of the supervisory stress test (also known as the Dodd-Frank Act Stress Test or DFAST, as these tests are required by Section 165 of the...more
On December 15, 2020, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule (“Final Rule”) setting forth standards to apply to controlling shareholders of industrial banks that are not subject to consolidated...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 Dodd-Frank Act provided the Federal Reserve Board with limited authority over certain insurance holding companies with federally regulated banking subsidiaries, creating some tension with the general rule, embodied in the...more
In prepared remarks before the American Council of Life Insurer's Executive Roundtable (Naples, Florida, 9 January 2019), Federal Reserve Board (FRB) Vice Chairman for Supervision Randal Quarles provided the insurance...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
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
The U.S. Board of Governors of the Federal Reserve System approved a final rule, which implements section 165(e) of the Dodd-Frank Act, and establishes single-counterparty credit limits for bank holding companies and foreign...more
On March 14, 2018, the U.S. Senate approved the Economic Growth, Regulatory Relief and Consumer Protection Act, a bipartisan bill that would repeal or modify certain provisions of the Dodd-Frank Act and eliminate or ease a...more
The US House of Representatives voted 288-130 in favor of the Systemic Risk Designation Improvement Act of 2017 (H.R. 3312). The bill, introduced on July 19, 2017 and sponsored by Representative Blaine Luetkemeyer, removes...more
Federal Reserve and FDIC Post Resolution Plans for Eight Major Financial Firms - On July 5, 2017, the Federal Reserve Board (the "Board") and the Federal Deposit Insurance Corporation ("FDIC") posted the public portions of...more
The US Board of Governors of the Federal Reserve System released the scenarios to be used by banks and supervisors for the 2017 Comprehensive Capital Analysis and Review and stress test exercises (DFAST) mandated by the...more
On January 30, 2017, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) adopted a final rule (the “Final CCAR Rule”) that revises the capital plan and stress test rules under the Dodd-Frank Wall...more
The US Federal Reserve Board invited comment on a proposal to fully apply the Federal Reserve Board’s existing rating system for bank holding companies to savings and loan holding companies....more
In an unheralded Supervision and Regulation Letter (Letter) issued by the Board of Governors of the Federal Reserve System (Board) on December 3, 2015 (SR 15-15), the Board provided guidance to explain “Supervisory Concerns...more
The Board of Governors of the Federal Reserve System ("FRB") has requested comments on reissued proposed rules that would establish a single-counterparty credit limits ("SCCL") for domestic and foreign bank holding companies...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
On January 28, 2016, the Federal Reserve released its supervisory scenarios for the 2016 Comprehensive Capital Analysis and Review (CCAR) and for the Dodd-Frank Act stress tests. In 2016, CCAR includes 33 firms with $50...more
Why it matters - Capital planning and stress tests for bank holding companies and other institutions with assets over $10 billion have been finalized by the Federal Reserve Board of Governors. For bank holding companies...more
On December 3, 2015, the Board of Governors of the Federal Reserve System released Supervision and Regulation Letter 15-15, “Supervisory Concerns Related to Shareholder Protection Arrangements” (SR 15-15), offering guidance...more
On Friday, October 30, 2015, the Federal Reserve Board (“Board”) reaffirmed its commitment to both the bank holding company model and single point of entry resolution. In a departure from historical views of the purpose and...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 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