The Federal Reserve has approved its long-awaited Final Rule amending and restating the 165(d) resolution planning rule. The FDIC is expected to soon approve an identical rule.  The Final Rule is largely unchanged from the Federal Reserve’s and FDIC’s May 2019 joint 165(d) Rule Proposal, and among other things:

  • Creates

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The Federal Reserve has finalized its rules to further tailor the regulatory framework for enhanced prudential standards and the U.S. Basel III capital and liquidity requirements applicable to domestic banking organizations and foreign banking organizations (Final Tailoring Rules).  Compared to the proposed rules that the U.S. banking agencies…
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Congress now has three different cannabis bills and three different approaches before it. One approach, taken by the Secure and Fair Enforcement Banking Act (the SAFE Banking Act), is to focus specifically on the difficulties faced by the banking, insurance and payments sectors. Another approach, taken by the Strengthening the…
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In a long-awaited milestone, the SEC has proposed an update of Guide 3, the industry guide for banking organizations.  The proposal eliminates a number of the current requirements under Guide 3 and streamlines many of those that remain.  The three “new” credit quality ratios in the proposal are, in practice,…
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In response to what Treasury Secretary Steven Mnuchin called “Iran’s brazen attack against Saudi Arabia,” and following President Trump’s tweet ordering Treasury to “substantially increase Sanctions on the country of Iran,” today the Treasury Department’s Office of Foreign Assets Control (OFAC) imposed additional sanctions on the Central Bank of Iran…
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In the latest development in the complex and evolving sanctions targeting the Government of Venezuela, on September 9, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) issued General License (“GL”) 34,  The new GL authorizes transactions involving certain individuals that would otherwise be prohibited…
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As we look forward to fall, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, 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…
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Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Fall Focus Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and…
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The Department of Commerce added 46 more non-U.S. affiliates of Huawei Technologies Co., Ltd. to the Bureau of Industry and Security (BIS) Entity List, joining Huawei and 68 of its non-U.S. subsidiaries that were put on the list in May.  The Commerce Department also extended a temporary general license permitting…
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