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

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 CRA Reform: The OCC Is The First and (So Far) Only Regulator Out of the Gate

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 Treasury Calls for Banking Regulators to Harmonize and Modernize Permissible Activities of Banking Organizations

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 Visual Memorandum: Senate Bipartisan Banking Bill to Rebalance the Financial Regulatory Landscape

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 Federal Reserve Proposes New Guidance on Management of Large Financial Institutions

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 OCC Brings Common Sense to CRA Ratings

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 Federal Reserve Proposes New Guidance on Corporate Governance

The Board of Governors of the Federal Reserve System (Federal Reserve) has proposed a new rating system for large financial institutions (LFIs). This proposal is intended to more closely align the Federal Reserve’s supervisory rating system with its supervisory program for LFIs.

LFIs are (i) bank holding companies and non-insurance,
Continue Reading Federal Reserve Proposes New Supervisory Rating System for Large Financial Institutions

The Office of the Comptroller of the Currency (OCC) issued a Notice today requesting public comment on potential changes to the regulations implementing the Volcker Rule. The Notice focuses on four topics, though makes clear that the OCC invites comments on all aspects of the Volcker Rule regulations and their
Continue Reading OCC Seeks Input on Volcker Regulation Reforms

Guidelines on covered fund seeding extensions from the Federal Reserve yesterday, following on the heels of last Friday’s guidance for foreign excluded funds, is a hopeful sign that the freeze on Volcker Rule guidance is finally thawing.  Perhaps these green shoots signal that broader, common sense relief is coming.  Yesterday’s
Continue Reading Green Shoots for the Volcker Rule: a Thaw in the Guidance Freeze?

Ever since the final Volcker Rule regulations were made public in December 2013, foreign banks and their regulators have expressed concern about the extraterritorial reach of the Volcker Rule to certain foreign funds that have a foreign bank as sponsor or investor.  This policy issue has, as is often the
Continue Reading Federal Banking Agencies Recognize Unintended Consequences of Volcker Rule for Foreign Banks and Propose Temporary Solution