On December 22, just before many of us may have started turning to our holiday breaks, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)...more
In this Issue. The U.S. Securities and Exchange Commission (SEC) was very active this week, having (i) issued no-action relief allowing registered funds to engage in self-custody of interests in loans that are originated,...more
In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more
EDITOR'S NOTE - Working Weekends and Holidays. While most Americans were enjoying the Independence Day holiday weekend, the Board of Governors of the Federal Reserve System (Federal Reserve), the Office of the Comptroller of...more
Bank, nonbank, and Fintech providers of consumer financial products and services may be able to reduce their exposure to compliance risk under the December 13, 2018 No Action Letter (“NAL”) Policy changes proposed by the...more
Editor's Note - In This Issue. The Securities and Exchange Commission (SEC) granted no-action relief for fund boards; the Financial Stability Oversight Council (FSOC) announced the rescission of the “systemically important...more
The US federal banking agencies with responsibility for enforcing the Volcker Rule have issued temporary one year no-action relief with respect to certain private non-US investment funds that are not “covered funds” for...more
Section 13 of the Bank Holding Company Act of 1956, as amended, and its implementing regulations (the “Volcker Rule”) generally prohibit a “banking entity” from engaging in proprietary trading and from investing in,...more
Editor's Note - In This Issue. The Senate confirmed Jay Clayton as the new chairman of the U.S. Securities and Exchange Commission (SEC), the Federal Deposit Insurance Corporation (FDIC) released its final handbook for...more
Regulatory Developments - Client Alert: Volcker Rule Conformance Period for Legacy Covered Fund Activities Extended One Year - On July 7, the Board of Governors of the Federal Reserve System announced that it has...more