Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
During the Trump Administration’s first year in office, it has implemented major new policy approaches and engaged in significant reversals of Obama Administration policies in many areas. In contrast, the Administration to...more
President Trump campaigned on reversing many Obama-era policies, and he is making good on his promises. The uncertainty of which major regulatory changes are in the pipeline is certainly keeping the legal community on its...more
The U.S. Department of the Treasury (Treasury) recently released a report examining the regulatory framework for the asset management and insurance industries (Report). The Report is the third in a series of four reports that...more
The Situation: The Volcker Rule's complexity has created uncertainty and compliance burdens that adversely affect market liquidity, risk hedging, and other economically important activities. The Opportunities: Bank...more
On Friday, July 28, 2017, Treasury Secretary Mnuchin will preside over an executive session of the Financial Stability Oversight Council (Council) at the Treasury Department. The preliminary agenda includes a discussion about...more
On June 8, 2017, the House of Representatives passed an amended version of H.R. 10, the Financial CHOICE Act of 2017, or CHOICE Act 2.0, which scales back or eliminates many of the post-crisis financial reforms that were...more
In a vote along party lines, the House of Representatives passed the Financial CHOICE Act of 2017, which would eliminate or scale back many of the provisions found in the Dodd-Frank Wall Street Reform and Consumer Protection...more
On June 12, 2017, the U.S. Treasury Department released a 150-page report (the Report) that recommends revamping many of the rules for banks and other financial services firms put in place after the 2008 financial crisis...more
On June 8, 2017, the House passed H.R. 10, the Financial “CHOICE” Act with a vote of 233 to 186. Introduced on April 27, 2017, the Financial CHOICE Act proposes to amend the Dodd-Frank Act to repeal the Volcker Rule,...more
What if Dodd-Frank and Basel III were to largely go away? Eliminating Dodd-Frank has been a hobbyhorse of Representative Hensarling, the chair of the House Services Committee, for several years and has figured prominently in...more
The presidential election has opened the possibility of significant changes to the Dodd-Frank Act regime that has been implemented over the last six years. It remains to be seen what plans the incoming administration will...more
Dechert partner Thomas P. Vartanian published an article entitled, "Open Letter to Trump: Weigh the Costs of Regulation," in the November 11 issue of the American Banker. While noting that it is undisputed that federally...more
Election Day brought an end to a long period of uncertainty that caused market fluctuations and delayed business planning decisions. As we navigate the post-election landscape, many questions remain regarding the potential...more
Campaign promises rarely turn into specific actions, but when they do, they are necessarily impacted by the dynamics of the legislative process. History suggests, however, that the policies of candidates can be a predictor of...more
On September 13th, the House Financial Services Committee approved the Financial CHOICE Act of 2016 to repeal and replace key parts of the 2010 Dodd-Frank law by a largely partisan vote of 30 to 26. Democrats declined to...more
Where do we go from here? As we mark another milestone in regulatory reform with the fourth anniversary of the enactment of the Dodd-Frank Act, it strikes us that although most studies required to be undertaken by the Act...more
The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the "SEC") issued a final rule, and the Commodity Futures...more
The “Volcker Rule,” enacted into law on July 21, 2010 as Section 619 of the Dodd- Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), subject to certain exceptions, prohibits a “Banking Entity” from...more