On July 27, 2023, the US banking regulators issued a notice of proposed rulemaking (the “NPR”) to revise significantly the risk-based capital requirements applicable to large banks and to banks with significant trading...more
In Short - The Situation: The federal banking agencies approved a proposal that would implement a "gold-plated" U.S. version of the "Basel III endgame."...more
Having had a front-row seat in the last banking crisis in 2008/9, one of the lessons that I thought everyone learned was the need for stable and consistent regulations regarding bank capitalization....more
In This Issue. The federal bank regulators published frequently asked questions concerning the London Interbank Offered Rate transition; the Consumer Financial Protection Bureau (CFPB) confirmed an effective date for two...more
The OCC, the Federal Reserve Bank, and the FDIC (collectively, the Banking Regulators) announced an interim final rule on March 9 that revises their capital rules to facilitate implementation of the US Treasury Department’s...more
In this Issue. The Office of the Comptroller of the Currency (OCC) issued guidance on its authority to charter limited purpose trust companies, raising the possibility that a limited purpose national bank could be organized...more
In the News. The Securities and Exchange Commission (SEC) announced that it adopted Rule 12d1-4 under the Investment Company Act of 1940 (the 1940 Act), providing a new regulatory framework for fund-of-funds and final...more
In the News. The Consumer Financial Protection Bureau (CFPB), along with the Federal Trade Commission (FTC) and more than 50 federal and state law enforcement partners, announced Operation Corrupt Collector, a nationwide law...more
Priming the Pump. As the COVID-19 outbreak continues, the Board of Governors of the Federal Reserve System (Federal Reserve), consistent with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), took additional...more
The community bank leverage ratio framework (CBLR Framework) is available for use beginning with the March 31, 2020 Call Report and Form FR Y-9C (consolidated financial statements for holding companies). A qualifying...more
Because the Nissan leadership scandal is about as well-contained as Chernobyl in the early days [thanks, HBO], French automaker Renault has voted this morning to remove Chief Executive Thierry Bolloré amid concerns over the...more
Insurers that own depository institutions (DIs), mainly mutual insurers owning savings and loans (S&Ls), have been waiting since the 2010 adoption of the Dodd-Frank Wall Street Reform and Consumer Protection Act for specific...more
On March 18, the extended comment period ended for the Standardized Approach for Calculating the Exposure Amount of Derivative Contracts (“SA-CCR”) rule (the “Proposed Rule”) proposed by the Federal Reserve Board (“Board”),...more
The U.K. Prudential Regulation Authority has published a draft modification of its capital rules to correspond with changes made to the Capital Requirements Regulation II that will apply directly in Member States from June...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
The U.S. Board of Governors of the Federal Reserve System, U.S. Office of the Comptroller of the Currency and U.S. Federal Deposit Insurance Corporation announced proposed revisions to the agencies’ regulatory capital rules...more
On March 23, 2018, President Donald Trump signed the Consolidated Appropriations Act of 2018 into law. This legislation includes the Small Business Credit Availability Act (SBCA), which contains numerous changes to...more
On September 27, 2017, the FDIC, the Federal Reserve, and the OCC (the “Agencies”) issued a proposed rule that simplifies the compliance requirements of the existing regulatory capital rules and is intended to reduce the...more
FHFA Updates Progress on Fannie Mae and Freddie Mac Credit Risk Transfer Programs - On November 22, 2017, the Federal Housing Finance Agency ("FHFA") issued a status report on credit risk transfer transactions done in...more
Bipartisan Regulatory Relief Bill for Smaller Financial Institutions Introduced in Senate Bipartisan legislation has been introduced in the U.S. Senate, aimed at reducing regulatory burden on community banks, providing new...more
Agencies Propose Simplifying Regulatory Capital Rules - On September 27, 2017, the Federal Deposit Insurance Corporation, the Federal Reserve Board and the Office of the Comptroller of the Currency announced a proposed...more
Federal Reserve Seeks Comments on LIBOR Alternatives - On August 24, 2017, the U.S. Federal Reserve requested public comments on a plan for the New York Federal Reserve and the Office of Financial Research to come up with...more
Since 2013, the International Association of Insurance Supervisors (IAIS), an association of insurance supervisors representing more than 200 jurisdictions in approximately 200 countries, has been working on a plan to develop...more
At the NAIC’s tenth International Insurance Forum, Daniel K. Tarullo, a member of the Board of Governors of the Federal Reserve System (FRB), outlined the FRB’s plans for: - ..the capital and liquidity rules for...more
A lawsuit over an alleged Ponzi scheme involving a fund pushed by MetLife agents is raising hard questions for the insurance giant over the reaches of corporate liability...more