News & Analysis as of

Federal Reserve Office of the Comptroller of the Currency

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M

by Ballard Spahr LLP on

The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2018 through...more

GAO Determines Leveraged Lending Guidance is a "Rule" under Congressional Review Act

by White & Case LLP on

On October 19, 2017, the Government Accountability Office ("GAO") determined that the Interagency Leveraged Lending Guidance ("LLG") issued by three federal banking agencies, the Board of Governors of the Federal Reserve...more

Proposed Regulatory Updates Will Require Increased Analysis of New Loans to Determine if Different Risk Weight Exposures Apply

by Steptoe & Johnson PLLC on

On September 27, 2017, the principal federal banking agencies, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, released a Notice of...more

The U.S. Government Accountability Office Determines That 2013 Leveraged Lending Guidance Is a Rule

by Shearman & Sterling LLP on

On October 19, 2017, the United States Government Accountability Office (GAO) issued an opinion determining that the 2013 Interagency Guidance on Leveraged Lending (the “2013 Guidance”), issued jointly by the Office of the...more

Orrick's Financial Industry Week In Review

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

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 rule intended to decrease regulation under these entities’...more

An Overview of the Volcker Rule

by K&L Gates LLP on

This practice note provides an overview of the Volcker Rule, which was enacted in 2010 as Section 619 of the comprehensive Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and codified as the new...more

It’s Not Much, but It’s a Start: The Regulators Freeze Certain Capital Requirements

by Vedder Price on

On August 22, 2017, the Office of the Comptroller of the Currency (the “OCC”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Board of Governors of the Federal Reserve System (the “FRB”) (the OCC, FDIC and FRB...more

Federal Regulatory Agencies Announce Coordination of Reviews for Certain Foreign Funds Under “Volcker Rule”

On July 21, 2017, the Board of Governors of the Federal Reserve System, the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation, the Office of Comptroller of the Currency and the Securities and...more

D.C. District Court Allows Payday Lenders’ Due Process Claims To Proceed In Case Against “Operation Choke Point”

by Ballard Spahr LLP on

On July 5, 2017, the U.S. District Court for the District Columbia, in the lawsuit filed in 2014 challenging “Operation Choke Point” — a federal enforcement initiative involving various agencies, including the Consumer...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Big American banks (BofA, Citi, Morgan Stanley) are avoiding deals with Chinese conglomerate HNA Group over concerns regarding HNA’s debt level and ownership structure....more

Nutter Bank Report, June 2017

Supreme Court: Bank That Buys Debt for Its Own Account Is Not Debt Collector - The U.S. Supreme Court recently held that a bank that collects on debts it has bought and holds “for its own account” is not a debt collector...more

GAO Agrees to Decide the Legality of the Leveraged Lending Guidance; Indicates Decision Will Take “at Least a Few Months”

On May 23, the Government Accountability Office (GAO), in a letter to Senator Patrick Toomey, R-Pa., agreed to determine whether the Guidance on Leveraged Lending jointly issued in 2013 by the Board of the Governors of the...more

The Financial CHOICE Act Is Approved by US House Financial Services Committee

On May 4, the Financial CHOICE Act (the FCA) — which was introduced to the House of Representatives on April 26 by Rep. Jeb Hensarling (Texas-5), and co-sponsored by seven of his Republican colleagues and referred for...more

Financial Services Weekly News - May 2017 #2

by Goodwin on

Editor's Note - In this Issue. The House Financial Services Committee passed the Financial CHOICE Act that would make significant changes to the Consumer Financial Protection Bureau; the U.S. Securities and Exchange...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

Wells Fargo’s Board Chair, Stephen Sanger, did survive his reelection vote the other day. Barely. But Breakingviews thinks he should think awfully hard about his future as a Director at the bank....more

Nutter Bank Report, March 2017

Fed Raises Threshold That Triggers Review of Systemic Risk of a Proposed Merger - In a recent decision on a proposed merger of two bank holding companies, the Federal Reserve indicated that it has increased the...more

Financial Services Weekly News - March 2017 #4

by Goodwin on

Editor's Note - The Battle Over the Proposed OCC FinTech Charter Continues. The Office of the Comptroller of the Currency (OCC) has released a draft supplement to its Licensing Manual explaining the process for FinTech...more

Orrick's Financial Industry Week In Review

SEC Approves Rules to Ease Investor Access to Exhibits in Company Filings - On March 1, 2017, the Securities and Exchange Commission (SEC) voted to adopt rule and form amendments that will require issuers to include a...more

Agencies Release Swap Margin Guidance

On February 23, 2017, the Federal Reserve Board (Board) and the Office of the Comptroller of the Currency (OCC) issued guidance regarding how supervisors should examine for compliance with the swap margin rule. The swap...more

US and EU Regulators Provide Relief for Compliance with Variation Margin Requirements

by White & Case LLP on

The CFTC, the Federal Reserve Board and the Office of the Comptroller of the Currency have taken action to extend the period during which Swap Dealers can comply with the requirement to post and collect variation margin under...more

Financial Services Weekly News - March 2017

by Goodwin on

Editor's Note - In This Issue. The New York Department of Financial Services issued its highly anticipated cybersecurity regulation in its final form, the Securities and Exchange Commission (SEC) issued updated guidance...more

The Federal Reserve and OCC Guidance Regarding Initial Examinations for Compliance with Variation Margin Rules for Non-Cleared...

by Morrison & Foerster LLP on

Last week the Board of Governors of the Federal Reserve System (the “Federal Reserve”) and the Office of the Comptroller of the Currency (the “OCC” and, collectively with the Federal Reserve, the “Banking Agencies”) released...more

Update: Prudential Regulators Delay Compliance Deadline for New Swap Margin Rules

by Pepper Hamilton LLP on

If you have been following our alerts on the pending deadlines (and the delays of these deadlines by certain regulators) of the new swap variation margin rules (New Swap Margin Rules) that were due to go into effect on March...more

European Regulators to Take Risk-Based Approach to Variation Margin Compliance

by McGuireWoods LLP on

On February 23, 2017, the European Supervisory Authorities (ESAs) announced that neither the ESAs nor competent authorities (CAs) would provide over-the-counter (OTC) derivatives dealers subject to European Market...more

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Cybersecurity

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