Too Big To Fail in the Dodd-Frank Era
Rodge Cohen: Dodd-Frank Fixes "Too Big To Fail"
The Financial Stability Oversight Council unanimously approved an analytic framework for financial stability risk identification, assessment and response and interpretive guidance on nonbank financial company determinations...more
Insurance and Investment Firms Breathe Easier - On December 4, 2019, the Financial Stability Oversight Council adopted final interpretive guidance on addressing systemic threats to the financial system that prioritizes the...more
The Financial Stability Oversight Council Improvement Act of 2019 (the “Act”) was recently introduced in the United States Senate. Under existing law, the Financial Stability Oversight Council (“FSOC”) can subject certain...more
In prepared remarks before the American Council of Life Insurer's Executive Roundtable (Naples, Florida, 9 January 2019), Federal Reserve Board (FRB) Vice Chairman for Supervision Randal Quarles provided the insurance...more
The Federal Reserve bank released the minutes from its September meeting yesterday. Among other things, we learned that the Fed Governors moved largely in lockstep on September’s rate hike, even as the crew was less unanimous...more
Marketing Private Life Insurance Separate Accounts to Smaller Banks - Subject to certain exceptions, the so-called “Volcker rule” provisions of the Dodd-Frank Act and regulations thereunder (collectively, the Volcker Rule)...more
On March 14, 2018, the U.S. Senate approved the Economic Growth, Regulatory Relief and Consumer Protection Act, a bipartisan bill that would repeal or modify certain provisions of the Dodd-Frank Act and eliminate or ease a...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
As we’ve been expecting, the DOJ announced yesterday that it was suing to block AT&T’s $84.5 billion bid for Time Warner over antitrust concerns....more
Uber’s got more than a spot of bother on its hands in London after this morning’s announcement that the company’s largest market in Europe won’t renew the ride-hailing service’s license to operate in the city (citing “a lack...more
The Board of Governors of the Federal Reserve (FRB) on August 3, 2017 issued a notice inviting comment regarding Proposed Guidance on Supervisory Expectations for Boards of Directors (Proposal). The Proposal applies to boards...more
The US Federal Reserve Board and the FDIC posted the public portions of the required “targeted submissions” for eight systemically important US banking institutions...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
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
On June 7, 2016, House Financial Services Committee Chairman Jeb Hensarling (R-TX) released an executive summary of the Financial CHOICE Act (the “FCA”), his highly anticipated bill to revisit the Dodd-Frank Wall Street...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 Dodd-Frank Wall Street Reform and Consumer Protection Act was enacted as a measure to promote financial stability and protection for consumers through increased regulation of nearly every aspect of the consumer finance...more
FINRA’s Retrospective Rule Review Process Continues. On April 16, FINRA announced that the FINRA Board of Governors had authorized FINRA to publish a regulatory notice requesting comment on proposed amendments to Rules 2210...more
On February 26, the Federal Reserve Board extended until April 3 the comment period for its proposed rule to implement capital surcharges for the largest, most systemically important U.S. bank holding companies....more
The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 contains two sets of provisions for managing the insolvency of financial institutions. First, the legislation creates an Orderly Liquidation Authority...more
The U.S. House of Representatives recently voted to pass legislation (H.R. 5461) intended to clarify capital standards for insurance companies under the supervision of the Federal Reserve Board. The bill, sponsored by...more
The U.S. Government Accountability Office just issued a report on the Financial Stability Oversight Council's (“FSOC”) systemically important financial institution (“SIFI”) designation process, entitled “Further Actions Could...more
Federal Reserve Adopts Final Systemically Important Financial Market Utilities Rules - On Wednesday, December 5, 2013, the Federal Reserve Board (the "Federal Reserve") adopted final rules that amend Regulation HH...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