Davis Polk has submitted a comment letter on the Federal Reserve’s proposed supervisory guidance on board governance (which we summarized in a previous blog post).  Consistent with our previous blog posts on the proposed board guidance and separate management guidance  issued by the Federal Reserve for large financial institutions, … Read More

Responding to a 2016 request by the SEC (in consultation with the Treasury Department), FINRA recently reviewed the extent to which various FINRA rules apply to U.S. Treasury securities.  Following up on that analysis, on February 6, 2018, FINRA issued Regulatory Notice 18-05, requesting comment on whether it should … Read More

In his recent speech that we have covered in a series of blog posts, Federal Reserve Vice Chair for Supervision Randal Quarles announced that he would like the Federal Reserve to achieve “meaningful simplification of our framework of loss absorbency requirements,” referring to both the Federal Reserve’s capital and … Read More

For the first time in 30 years, Congress may expand the jurisdiction of the Committee on Foreign Investment in the United States (“CFIUS”).  In testimony before the Senate Banking Committee on January 25, 2017, three Administration officials expressed support for the Foreign Investment Risk Review Modernization Act of Read More

Vice Chair for Supervision Randal Quarles’ announcement that the Federal Reserve is re-examining its framework for making control determinations under the Bank Holding Company Act is a welcome development.  In critiquing the control framework, which has developed piecemeal over decades, Vice Chair Quarles called it “complex and occasionally opaque” and … Read More

Cyber threats remain a key operational concern for banks, which are otherwise experiencing “near-historic” capital and liquidity highs and improved returns on equity, according to the Office of the Comptroller of the Currency (the “OCC”).  The regulator published its Fall 2017 Semiannual Risk Perspective on January 18th, stating … Read More

Federal Reserve Vice Chair for Supervision Randal Quarles recently sought to answer the question that he has been asked most frequently since assuming his post three months ago: What’s next? He expressed his support for the reforms that have made the financial system stronger and more resilient since the Financial … Read More

The CFPB’s announcement of a call for evidence is a welcome sign that the new leadership of the agency is thinking seriously about how it implements its mission. In the coming weeks the CFPB will publish a series of Requests for Information (RFIs) seeking public comment on the CFPB’s enforcement, … Read More