Do Banks Still Need Holding Companies?
The Federal Reserve has announced that its FedNowSM Service, a new interbank settlement service with clearing functionality to support instant payments, went live on July 20 with 35 early-adopting banks and credit unions. The...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
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 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
On June 14, 2018, the Federal Reserve Board (the “Board“) approved a rule to limit the concentration of risk between global systemically important bank holding companies (“GISB“) and their counterparties. ...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 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
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
Three federal banking regulatory agencies have approved an advance notice of proposed rulemaking (ANPR) inviting comment on a set of potential enhanced cybersecurity risk-management and resilience standards that would apply...more
Updating Unregistered Structured Note Programs: How Frequently? - For some types of securities offering programs, we have “black letter law” that instructs issuers how frequently the program documentation should be...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
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
The Board of Governors of the Federal Reserve System (“Board”) in December 2012 issued a proposed rule under the Dodd-Frank Act (“DFA”) for the enhanced supervision of foreign banking organizations (“FBOs”) and any foreign...more