On July 27, 2023, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, FBAs) issued their long-awaited...more
Governor Bowman calls for transparent supervisory expectations and attention to the consequences of regulatory reform on the broader financial system. On June 25, 2023, US Federal Reserve Board (FRB) Governor Michelle W....more
On April 28, 2023, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the United States Government Accountability Office (GAO), and the New York Department of...more
In contrast with the White House’s position, the Vice Chairman denied that loosened Dodd-Frank rules contributed to the recent bank failures. On April 12, 2023, Federal Deposit Insurance Corporation (FDIC) Vice Chairman...more
On March 10, 2023, the United States suffered the first major bank failure since the 2008 economic collapse. It was the nation’s 16th largest bank, with over $200 billion in assets....more
The Federal Reserve, OCC and FDIC have (finally) issued the Final HVCRE Rule (for background, our analysis of the 2018 Notice of Proposed Rulemaking and 2019 Notice of Proposed Rulemaking are here and here), regarding High...more
OCC and FDIC Propose Interest Rate Fix for Loans Transferred to Non-Banks - The FDIC and OCC have separately proposed rules that would codify the “valid-when-made” doctrine and clarify that when a bank sells, assigns, or...more
Federal Banking Agencies Adopt Simplified Capital Calculation for Community Banks The federal banking agencies have issued a final rule that will simplify capital requirements for community banks by allowing them to adopt...more
FDIC Shares Examiners’ Expectations for Contracts with Technology Service Providers - The FDIC has issued guidance on examiners’ expectations for provisions of contracts between banks and technology service providers...more
Federal Banking Agencies Propose Alternative Capital Framework for Community Banks - The federal banking agencies have proposed a new community bank leverage ratio (“CBLR”) framework that would simplify regulatory capital...more
On November 20, the Federal Reserve Board (FRB) and CFPB jointly proposed amendments to Reg. CC, which implements the Expedited Funds Availability Act (EFA Act), and also reopened for public comment various amendments that...more
On October 2, 2018, the U.S. Senate’s Banking Committee held a hearing to review regulators’ implementation of the Economic Growth, Regulatory Relief and Consumer Protection Act (S.2155) since its passage in June. As framed...more
Since my last post, the Economic Growth, Regulatory Relief, and Consumer Protection Act (which some are referring to as EGRRCPA – oof.) was signed into law by President Trump on May 24th. Section 214, titled, “Promoting...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