Mr. Paridon is counsel in Davis Polk’s Financial Institutions Group. [Full Bio]

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
Continue Reading

The Federal Reserve, OCC, FDIC, SEC and CFTC adopted final amendments on July 9, 2019 implementing the small-bank exclusion and name-sharing provisions of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final amendments modify the definition of “insured depository institution” and also permit a covered
Continue Reading

The Federal Reserve has requested comment on a highly anticipated notice of proposed rulemaking to amend its regulatory framework for deciding when a company exercises a controlling influence over another company under the Bank Holding Company Act and the Home Owners’ Loan Act.

The proposal is a welcome step in
Continue Reading

The Federal Reserve, FDIC and OCC (the Banking Agencies) recently published a proposal to increase the thresholds associated with the “major assets” prohibition governing management official interlocks contained in the Depository Institutions Management Interlocks Act (DIMIA)[1] and implemented by Regulation L.  DIMIA permits the Banking Agencies to raise the
Continue Reading

In a laudable step towards further advancing a reform of the Community Reinvestment Act (“CRA”), the OCC earlier this week released an advanced notice of proposed rulemaking (the “ANPR”) “to solicit ideas for building a new framework to transform and modernize” the current CRA regulatory framework
Continue Reading

The U.S. financial services industry continues to be faced with changes in technology – machine learning, database capabilities, automated process, and innovative products – that change the manner, speed and security with which financial services and products can be provided.  Those of us familiar with the longer term evolution of
Continue Reading

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
Continue Reading

The Federal Reserve’s proposed core principles on management of large financial institutions are another welcome addition to its efforts to clarify and better distinguish between the roles of boards of directors and the management of large financial institutions. The new guidance (Management Guidance) describes core principles of effective senior management,


Continue Reading

The OCC’s recent revision to its Community Reinvestment Act examination and ratings policies is a welcome first step in a long overdue and much needed rethink of how supervisors might modernize the CRA so that the statutory goal of helping underbanked communities can be met in the digital era.  The
Continue Reading

The Federal Reserve has proposed changes to its guidance on corporate governance for banking organizations, which refocus its supervisory expectations more clearly on a board’s core responsibilities. The proposal distinguishes more clearly the roles and responsibilities of boards and senior management, eliminates redundant and outdated SR letters and guidance, and
Continue Reading