In the decade leading up to the 2008 financial crisis, de novo bank charters averaged more than 100 per year.[1] This robust flow of new bank charters continued a trend since the 1960s and before.[2] It partially offset a decline in the number of banks in the United
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Alison M. Hashmall
Ms. Hashmall is an associate in Davis Polk's Financial Institutions Group. [Full Bio]
OCC Grants Conditional National Bank Charter to a Mobile-Only Bank
Posted in Bank Regulation, FinTech
The Office of the Comptroller of the Currency (OCC) has granted conditional approval to digital-banking startup Varo Bank (previously Varo Money) of its application to form a de novo national bank. Varo Bank, N.A. would become the first mobile-only national bank in United States. This is an interesting…
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Davis Polk Comments on Federal Reserve’s Proposed Guidance on Board Governance
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,…
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Federal Reserve May Simplify the TLAC Rule
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…
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Treasury’s Recommendation for FSOC: No CHOICE but to Play Double Duty
Posted in FSOC
The Trump Treasury Department’s vision for how the FSOC should fulfill its mission is emerging.[1] Ironically, this new, and we think better vision, may be closer to how the Obama Treasury Department originally conceived the FSOC’s role. In essence, we read the implicit Treasury viewpoint to be that the over-focus…
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Volcker Rule Commenters Largely Support Reforms
By Randall D. Guynn, Jai R. Massari, Gabriel D. Rosenberg, Alison M. Hashmall, Craig D. Kennedy & Kirill Lebedev on
Posted in Volcker Rule
The Office of the Comptroller of the Currency (the “OCC”) took a first formal step in evaluating how the regulations implementing the Volcker Rule should be revised by issuing a request for public input on the regulations in early August, with comments due in late September. Of the 55 comment…
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