Andrew Rohrkemper

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Mr. Rohrkemper is an associate in Davis Polk's Financial Institutions Group. [Full Bio]

Here is Davis Polk’s two-page overview of the Federal Reserve’s actions to address the coronavirus crisis, with embedded links to the primary materials on the Federal Reserve’s website. This version is updated to cover the new, sweeping measures that the Fed announced on the morning of Monday, March 23, 2020.  …
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The Federal Reserve announced a further expansion of the Money Market Mutual Fund Liquidity Facility (MMLF), originally announced on March 18, 2020 and expanded on March 20, 2020, as part of its response to the coronavirus crisis.  Under the further expanded MMLF, additional securities are eligible as collateral.…
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The Federal Reserve announced an expansion of the Money Market Mutual Fund Liquidity Facility (MMLF) originally announced on March 18, 2020 as part of its response to the coronavirus crisis.  Under the expanded MMLF, certain municipal bonds are eligible as collateral and certain municipal MMFs are eligible for…
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The U.S. banking agencies have completed one of the most important steps towards rebalancing the U.S. bank regulatory framework since the Dodd-Frank Act was passed in the wake of the 2007 – 2008 financial crisis.  The agencies have adopted final rules to tailor enhanced prudential standards and U.S. Basel III…
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The U.S. banking agencies have released a final rule amending the U.S. Basel III capital rules to simplify the capital treatment of capital deductions and recognition of minority interests for non-advanced approaches banking organizations, as well as implementing certain technical amendments applicable to both advanced approaches and non-advanced approaches banking…
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The U.S. banking agencies have proposed allowing custodial banking organizations to exclude certain central bank deposits from the calculation of total leverage exposure, the denominator of the U.S. Basel III supplementary leverage ratio (SLR).  The proposal implements Section 402 of the Economic Growth, Regulatory Relief and Consumer Protection…
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The move away from a one-size-fits-all regulatory framework based on asset size continues.

On October 31, the Federal Reserve proposed a rule to implement Section 401 of the Economic Growth, Regulatory Relief and Consumer Protection Act, tailoring enhanced prudential standards for firms with $100 billion or more in total consolidated…
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The three Federal banking agencies jointly released an interim final rule on August 22, 2018 that amends the agencies’ respective liquidity coverage ratio (LCR) rules to treat as level 2B high-quality liquid assets (HQLAs) any municipal obligation that is both (1) “liquid and readily marketable” and (2) “investment grade.”  The…
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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…
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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…
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