On January 30, 2020, the Federal Reserve Board, OCC, FDIC, SEC and CFTC (the Agencies) proposed amendments to the covered fund provisions of the Volcker Rule. The proposed amendments address long-standing concerns with the over-broad definition of covered fund, the treatment of foreign funds (both public and private), and the…
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On January 13, 2020, the U.S. Treasury Department promulgated its final regulations implementing the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) to reform the authority and jurisdiction of the Committee on Foreign Investment in the United States (CFIUS). The final regulations were released in two parts: one addressing…
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In a welcome move, two recent actions by the Federal Reserve, OCC and FDIC (the Banking Agencies) recognize the increasing role of fund complexes and passive investing.  The Banking Agencies have released a statement under the Federal Reserve’s Regulation O which acknowledges the reality that equity mutual funds may sometimes…
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In a step forward for the digital transformation of banking and partnerships between banks and FinTechs, the FDIC released proposed changes to its brokered deposit regulations in late December 2019. The proposed changes are designed to update the regulatory framework as much as possible within the constraints of the existing…
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On January 10, 2020, President Trump issued Executive order 13902 (“E.O. 13902”) which authorizes the U.S. Department of the Treasury to impose additional sanctions targeting the construction, mining, manufacturing and textiles sectors of the Iranian economy, as well as any other sector of the Iranian economy subsequently specified by the…
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The Financial Stability Oversight Council’s (FSOC) recently revised guidelines (the 2019 Guidelines) on how it will identify and address financial stability risks are a major shift from the guidelines it issued in the immediate aftermath of the Financial Crisis.  The 2019 Guidelines draw upon lessons learned from…
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On December 10, 2019, the CFTC reopened the comment period for the proposed capital requirements for swap dealers (SDs) and major swap participants (MSPs) that are not subject to the capital rules of a prudential regulator (together, Covered Swap Entities).  These rules are the last…
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As we enter the new year, we have updated our roster of federal financial regulatory leadership, including announced nominations, confirmations, resignations and expiring terms.  The first slide summarizes the state of play for the agencies’ principals; the later slides provide a deeper look on an agency-by-agency basis, including select senior…
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Financial services regulatory reform will continue to be active in 2020, with developments percolating in all three branches of government.  As we observe the changing landscape, here is the 2020 Vision Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas,…
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The CFTC’s Division of Swap Dealer and Intermediary Oversight (“DSIO”) issued an advisory on December 4, 2019 to provide further guidance regarding the preparation and submission of chief compliance officer (“CCO”) annual compliance reports (“CCO Annual Reports”) for swap dealers (“SDs”), futures…
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