First Republic Executives Fail in Attempt to Recover Nonqualified Deferred Compensation Plan Assets
Consumer Finance Monitor Podcast Episode: Interest Rate Exportation Under Attack Part II
Consumer Finance Monitor Podcast Episode: Interest Rate Exportation Under Attack Part I
Consumer Finance Monitor Podcast Episode: Banks and Their Customer Relationships: What is the Appropriate Role of Bank Regulators?
Compliance into the Weeds: Scathing Report on Culture at The FDIC
2024 Regulatory Hot Topics
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
Consumer Finance Monitor Podcast Episode: What the Recent Developments in Federal Preemption for National and State Banks Mean for Bank and Nonbank Consumer Financial Services Providers
Federal Banking Interagency Final Guidance on Third-Party Relationships - The Consumer Finance Podcast
Evaluating Government Sanctions in the Payments Industry - Payments Pros: The Payments Law Podcast
Consumer Finance Monitor Podcast Episode: A Deep Dive Into Cryptocurrency and its Risks to Investors and the Banking System, with Arthur E. Wilmarth, George Washington University Law School
CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast
CFPB's Policy Statement on Abusiveness (Part 1) - The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: How a Former FDIC Chairman is Reacting to the Silicon Bank Valley Failure, A Discussion with Special Guest Bill Isaac, Chairman, Secura/Isaac Group, and FDIC
Crypto Year in Review 2022: Federal Reserve and Central Bank Digital Currencies and FDIC/OCC Regulatory Developments - The Crypto Exchange Podcast
Use of the FDIC Name and Logo: Proceed With Caution
All Talk, No Action? The Fintech Regulatory Plot Thickens
Congressional and Federal Agency Action Following Executive Order on Digital Assets Policy
The Sanity of Bank Directors
Regulators Tackle Board Effectiveness and Overdrafts
Industry participants looked forward to 2016 with a great deal of anticipation considering both the implementation of the risk retention rules, and the expected wall of maturities. By mid-year the first commercial...more
On October 22, 2014, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, the Federal Housing...more
Effective December 24, 2015, all securitizations of residential mortgage loans (RMBS), both public and private, will be subject to the Credit Risk Retention Rule (the “Rule”).[1] The Rule was promulgated on December 24, 2014,...more
On July 20, the Department of the Treasury published a Notice and Request for Information (“RFI”) seeking comment on various aspects of online marketplace lending, including – - the business models and products offered...more
Six federal agencies approved on October 22 a final rule requiring sponsors of securitization transactions to retain risk in those transactions. The final rule implements the risk retention requirements in the Dodd-Frank Wall...more
The Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Department of Housing and Urban Development, Federal Housing Finance Agency, and...more
A final credit risk retention rule was recently issued with respect to asset-backed securities (ABS) by the prudential bank regulators (the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance...more
After three years of waiting, we now have our Risk Retention Rule. All six of the Agencies responsible for the Rule – the FDIC, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the...more
Six federal agencies approved a final rule requiring sponsors of securitization transactions to retain risk in those transactions. The final rule implements the risk retention requirements in the Dodd-Frank Wall Street...more
We will leave the hand wringing and teeth gnashing to others. We expect there will be a lot of that in the days ahead. We have had our say on the misguided premises and tortured statutory interpretation underpinning the final...more
Today, the Federal Deposit Insurance Corporation (the “FDIC”), the Federal Housing Finance Agency (the “FHFA”), and the Office of the Comptroller of the Currency (the “OCC”) each adopted a final rule (the “Final Rule”)...more
Well, Halloween has come and gone and with the annual bacchanal of faux frisson over zombies, vampires and the like behind us, can we also put away risk retention anxieties like one of those annoying and morally disturbing...more
Executive summary - Overview - On August 28, 2013, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System (Federal Reserve Board), the Federal Deposit Insurance...more
The new Risk Retention Rule published jointly by the FDIC, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Securities Exchange Commission, with a little help from...more
On August 28, 2013, six federal regulatory agencies (among them, the SEC, Federal Reserve, OCC and the FDIC (collectively, the “Agencies”)) released a 499 page second risk retention proposal (the “Second Proposal”). The...more
In 2011, the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Office of the Comptroller of...more
Agency Template for Tailored Resolution Plans - On September 3, the FDIC and the Fed released an optional model template for tailored resolution plans required to be submitted by the Dodd-Frank Act. SEC Risk...more
Joint Proposal on Risk Retention - On August 28, the FDIC, Fed, FHFA, OCC, SEC and HUD issued a notice of revised proposed rulemaking relating to required risk retention by sponsors in securitization transactions. The...more
On August 28, the FDIC, Fed, FHFA, OCC, SEC and HUD issued a notice of revised proposed rulemaking relating to required risk retention by sponsors in securitization transactions....more
On August 28, 2013, the FDIC, OCC, FRB, SEC, Federal Housing Finance Agency, and Department of Housing and Urban Development (collectively, the “Agencies”) issued a second Notice of Proposed Rulemaking (the “revised...more
CLO managers and lead arrangers of syndicated loans received special attention in a proposal jointly released by six federal agencies to implement the credit risk retention requirements of Section 941 of the Dodd-Frank Act....more
On August 28, 2013, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the U.S. Securities and Exchange Commission, the Federal...more
At last count, we now have four separate risk retention regimes (maybe five) that we need (or will soon need) to deal with as we attempt to restructure any securitization. They are, of course, all different. And let’s be...more