On September 17, the Federal Deposit Insurance Corporation (FDIC) proposed a new rule that would significantly impact the risk management and oversight requirements for bank-fintech arrangements. This proposal comes in...more
The FDIC has issued a proposed rule that would apply to practically all bank-fintech arrangements that use custodial deposit accounts to provide customers with transactional features (also called "FBO" accounts for short)....more
On October 24, 2023, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (together, the “Agencies”) released their final Principles for Climate-Related...more
Since the 2008 financial crisis, a non-US bank seeking to establish or maintain a US presence has been required to comply with a set of stringent regulatory requirements, but a recently adopted rule (Final Rule) limits their...more
On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more
SEC Adopts Trade Acknowledgment and Verification Rules for Security-Based Swap Transactions - On June 8, 2016, the Securities and Exchange Commission publicized the implementation of "rules that will establish timely 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 Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 contains two sets of provisions for managing the insolvency of financial institutions. First, the legislation creates an Orderly Liquidation Authority...more
The five agencies that jointly issued the final Volcker Rule last December recently added to their existing list of “frequently asked questions” (FAQs) a new item addressing the attestation requirement applicable to CEOs of...more
Last week, the Federal Reserve Board (the “Board”) issued its long-awaited final enhanced prudential rule (Regulation YY) under Section 165 of the Dodd-Frank Act (the “Final Rule”) for bank holding companies and foreign...more