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Risk Management Financial Stability Oversight Council

Mayer Brown Free Writings + Perspectives

Financial Stability Oversight Council 2023 Annual Report

The Financial Stability Oversight Council recently released its annual report.  Not surprisingly, this year’s report reviewed the banking failures in the early part of the year.  In discussing the “vulnerabilities in the...more

ArentFox Schiff

New Federal Climate Change Guidance for Large Banks Outlines Risk Management Framework

ArentFox Schiff on

On October 24, US banking regulators, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (the “agencies”), issued long-awaited guidance...more

Venable LLP

Tinker, Tailor, Banker, FSOC Designation: New Guidance for Bank-like Regulation and Supervision of Non-Banks

Venable LLP on

Since the 2023 spring bank failures, the federal banking agencies have tinkered with significant bank regulations and guidance—ranging from capital, bail-in measures, and resolution planning to climate-risk stress testing,...more

Goodwin

Overdraft Protection Programs: Risk Management Practices

Goodwin on

Regulatory Developments - Overdraft Protection Programs: Risk Management Practices - On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more

Proskauer - Blockchain and the Law

New York Department of Financial Services Issues Cryptocurrency-Related Guidance to Banks, Increases Regulatory Scope

At a time when states are jockeying for position to become digital asset and cryptocurrency hubs and we’ve witnessed turmoil and regulatory uncertainty within the cryptoasset industry, the New York Department of Financial...more

McDermott Will & Emery

Climate Change and State Insurance Regulation: What Could Change After President Biden’s May 20 Executive Order

McDermott Will & Emery on

US President Joe Biden’s May 20, 2021, executive order laid out an aggressive, whole-of-government plan to address climate change risk, including a set of directives that will have a major impact on the operations of the...more

Kramer Levin Naftalis & Frankel LLP

Ranking Member of Senate Finance Committee Demands FSOC Address Risk in Leveraged Loan Market

In an April 11 letter to Treasury Secretary Mnuchin, in his capacity as chair of the  Financial Stability Oversight Council (FSOC), U.S. Sen. Sherrod Brown (D-Ohio), the ranking member of the U.S. Senate Committee on Banking,...more

Nutter McClennen & Fish LLP

Fintech in Brief: FSOC Issues 2018 Annual Report

On December 19, 2018, the Financial Stability Oversight Council (the “FSOC”) released its 2018 Annual Report (the “Report”). The FSOC was established by the Dodd-Frank Wall Street Reform and Consumer Protection Act to...more

Dechert LLP

Treasury’s Third Report on Financial System Regulation Focuses on the Asset Management and Insurance Industries

Dechert LLP on

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

Morrison & Foerster LLP

Treasury Department Urges Principles-Based Regulation of Money Managers; Delay of Implementation of Liquidity Risk Management and...

The U.S. Department of the Treasury’s report on asset management and insurance recommends, among other things, a delay in implementation of the SEC’s liquidity risk management rule and the Department of Labor’s fiduciary...more

Morrison & Foerster LLP

Investment Management Legal + Regulatory Update - August 2016

Regulation - Next on the SEC’s Regulatory Agenda: A Chief Valuation Officer? - First, the SEC required funds to designate a chief compliance officer. Then, the SEC proposed that funds designate a liquidity...more

Dechert LLP

US Federal Reserve Board Begins the Process of Regulating Insurance Companies

Dechert LLP on

Nearly six years after the adoption of Dodd-Frank’s Title I, which provides for the regulation by the Board of Governors of the Federal Reserve System (Board) of non-bank financial companies – such as insurance companies,...more

Manatt, Phelps & Phillips, LLP

FSOC on Fintech Risks, Cybersecurity Vigilance

An annual report from the Financial Stability Oversight Council (FSOC) recently focused on the risks presented by the burgeoning fintech industry as well as the continuing "pressing concern" of cyber threats and...more

Morrison & Foerster LLP

Next on the SEC regulatory agenda: a chief valuation officer?

First, the Securities and Exchange Commission required funds to designate a chief compliance officer. Then, the SEC proposed that funds designate a liquidity risk manager, and after that, a derivatives risk manager. Can a...more

Dechert LLP

MetLife Opinion Turns the Tables on FSOC: Back to the Drawing Board

Dechert LLP on

U.S. District Court Judge Rosemary Collyer recently released her opinion invalidating the decision of the Financial Stability Oversight Council (FSOC or the Council) to designate MetLife a systemically important financial...more

K&L Gates LLP

U.S. SEC Proposes Liquidity Risk Management Programs, Optional “Swing Pricing,” and Liquidity Reporting for Mutual Funds and...

K&L Gates LLP on

On September 22, 2015, the Securities and Exchange Commission (“SEC”) proposed a new rule and amendments to rules and reporting forms under the Investment Company Act of 1940 (the “1940 Act”), designed to standardize...more

Broker-Dealer Compliance + Regulation

SEC Expected to Propose Liquidity Risk Management Programs for Funds

The Securities and Exchange Commission announced that it will consider proposals for liquidity risk management programs and related disclosures for open-end management investment companies. The Commission will consider the...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more

Morrison & Foerster LLP

Dodd-Frank at 4: Where do we go from here?

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

Skadden, Arps, Slate, Meagher & Flom LLP

"Shadow Banking and Financial Stability: Regulators Propose Framework for Nonbank Noninsurers"

On March 4, 2015, the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO) issued a second consultation paper concerning the methodology they propose to use to identify nonbank...more

Stinson - Corporate & Securities Law Blog

GAO Says FSOC Needs to Improve Transparency, Accountability, and Collaboration

In testimony before a Congressional subcommittee, a GAO representative noted FSOC still lacks a comprehensive, systematic approach to identify emerging threats to financial stability. In 2012, GAO reported that FSOC’s...more

Morgan Lewis

SEC Proposes Enhanced Regulatory Framework for Certain Registered Clearing Agencies

Morgan Lewis on

The proposal is consistent with international recommendations and Basel III criteria. On March 12, the Securities and Exchange Commission (SEC) proposed new rules and rule amendments (the Proposal) that would enhance...more

Dechert LLP

U.S. Office of Financial Research Issues Report on Asset Management and Financial Stability

Dechert LLP on

The Office of Financial Research (“OFR”), an office of the U.S. Department of the Treasury, recently issued a report that may provide a roadmap for future designations by the Financial Stability Oversight Council (“FSOC”) of...more

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