The decision by the United States Court of Appeals for the Fifth Circuit earlier this week in Collins v. Mnuchin holding that the structure of the Federal Housing Finance Agency (FHFA) is unconstitutional is an important development not only for the FHFA but also for the constitutionality of … Read More
The Basel Committee on Banking Supervision last week published a revised assessment methodology to determine whether a banking organization is a global systemically important bank (“GSIB”) and a GSIB’s associated capital surcharge requirement. The revised methodology reflects the following changes from the current methodology, which are expected … Read More
Today, the Federal Reserve and FDIC released the public sections of the 2018 165(d) resolution plans of Barclays, Credit Suisse, Deutsche Bank and UBS, which were due on July 1, 2018. The plans contain strategies for the rapid and orderly resolution of each firm’s U.S. operations under the Bankruptcy Code … Read More
Our public memorandum here describes the notice of proposed rulemaking published by the CFTC on June 12, 2018 that would make permanent the $8 billion temporary swap dealer de minimis registration threshold currently in effect and would make other changes to the de minimis exception.
As we head into the July 4th holiday and the heart of summer approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations, resignations and expiring terms. The first slide summarizes the state of play for the agencies’ principals; … Read More
Financial services regulatory reform in 2018 continues to evolve. For those of you who have been thinking you might catch up over the summer lull, here is the summer beach read edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, … Read More
The Federal Reserve last week released the results of its 2018 Comprehensive Capital Analysis and Review (CCAR). We have analyzed the 2018 CCAR results, along with the Dodd-Frank Act Stress Test results published the previous week, and have prepared a graphical summary available here. As our summary shows, on … Read More
Today, the Federal Reserve and FDIC issued and invited comments on proposed guidance on the 2019 and subsequent submissions of the U.S. G-SIBs’ 165(d) resolution plans. The Proposed Guidance is available here.
The Proposed Guidance is largely similar to the guidance issued by the Agencies in April 2016, with … Read More
On June 27, 2018, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced amendments to the Iranian Transactions and Sanctions Regulations (“ITSR”), 31 C.F.R. part 560, and published updated answers to frequently asked questions (“FAQs”) to further implement President Trump’s May 8, … Read More
Arguments surrounding the constitutionality of the CFPB’s structure, never fully put to rest despite the D.C. Circuit’s en banc decision in PHH v. CFPB, are back in the headlines this week. Yesterday, Senior United States District Judge Loretta A. Preska of the Southern District of New York issued a … Read More