The Federal Reserve and the OCC have proposed a rule that would recalibrate the enhanced supplementary leverage ratio (eSLR) requirements applicable to U.S. GSIBs and their insured depository institution (IDI) subsidiaries, and related requirements, by tailoring the eSLR levels to 50 percent of each firm’s GSIB surcharge.  The proposal would … Read More

The Stress Buffer Requirements (SBR) Proposal would fundamentally restructure how the Federal Reserve’s stress testing and capital planning framework is used to impose capital requirements for large banking organizations.  In general, the proposal would shift the quantitative capital requirements based on a firm’s pro forma stress losses, which currently are … Read More

Citing the Russian government’s “range of malign activities around the globe,” on April 6, 2018, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) sanctioned seven Russian oligarchs and 12 companies they own or control, 17 senior Russian government officials, and a state-owned … Read More

Market Developments

Web Platforms Continue to Ban ICO-Related Advertisements

The SEC increasingly is focusing its enforcement authority not only on companies and individuals raising capital through Initial Coin Offerings (“ICOs”), but also on the “market participants – promoters, sellers, lawyers, officers and directors and accountants” who participate in … Read More

Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and provide updated versions … Read More

The Senate passed the Economic Growth, Regulatory Relief and Consumer Protection Act (S.2155) on March 14 by a filibuster-proof vote of 67 – 31.  The Senate bill still must pass the House, where Rep. Jeb Hensarling (R-TX) and other representatives have said they plan to propose a series of amendments … Read More

Last week, the U.S. Court of Appeals for the Fifth Circuit, in a 2-1 decision, vacated the DOL fiduciary rule in its entirety.  The lawsuit was brought by the U.S. Chamber of Commerce, SIFMA and a number of other business groups to challenge the validity of the fiduciary rule, … Read More

In the first major trading and markets initiative under SEC Chairman Jay Clayton, on March 14, 2018, the SEC proposed to establish a transaction fee pilot program to study the effects of maker-taker fee structures. A pilot study was initially recommended by the SEC’s Equity Market Structure Advisory Committee in … Read More

The Trump Administration has officially banned U.S. transactions in Venezuela’s controversial “petro” digital currency.  On March 19, 2018, the Trump Administration issued a new Executive Order, “Taking Additional Steps to Address the Situation in Venezuela” (the “Digital Currency E.O”), which prohibits U.S. persons and others subject to … Read More