Too Big To Fail in the Dodd-Frank Era
Rodge Cohen: Dodd-Frank Fixes "Too Big To Fail"
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 May 24, 2018, President Trump signed the Economic Growth, Regulatory Relief and Consumer Protection Act (the “Reform Act”). The bulk of reform in the Reform Act consists of the elimination of many technical and...more
On May 24, President Trump signed into law the most significant banking legislation since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) in 2010. The bill – named the Economic...more
The US House included the revised Volcker Rule that we’ve discussed in a broader package of Dodd-Frank reforms that it passed with bipartisan support last night. The bill—ostensibly aimed at easing restrictions on small to...more
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
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
While no one knows for sure what the future holds for investment management regulation, the tea leaves indicate that we may expect a slowdown on new regulations, some pullback on parts of the Dodd-Frank Wall Street Reform and...more
This commentary is not customarily about politics, although those with a subtle cast of mind might get an inkling of some my personal views from my always dry and balanced language. However, right now, it’s hard not to think...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
It’s still in the early days of 2014. I think it’s finally stopped snowing in the East, the sun has come out and the stock market is continuing to outperform the woe purveyors. Republicans and Democrats have gotten...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
Dear Clients and Friends: In October, federal agencies proposed two new sets of regulations under the Dodd-Frank Act. The proposals — to implement the Volcker Rule and to create standards to designate certain nonbanks...more
The Volcker Rule was advanced as a means of protecting the public from the risks of negative externalities and the effect of distorted incentives (or “moral hazard”) arising from proprietary trading activities by financial...more
An insurance company is a “covered banking entity” if it controls or is affiliated with an insured depository institution (as defined in Section 3(c) of the Federal Deposit Insurance Act), which includes any bank, thrift,...more
The Volcker Rule prohibits a banking entity from sponsoring or investing in a hedge fund or private equity fund, subject to certain exceptions. The proposed regulations expand the definitions of “hedge fund” and “private...more