The FDIC has issued a final rule to formalize longstanding expectations it has had for the parent company of a new industrial loan company (ILC). The FDIC adopted the proposed rule issued in March 2020 with few changes. The final rule requires a new ILC to enter into a written
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Ledina Gocaj
Fed Creates Secondary Market Corporate Credit Facility to Provide Liquidity to Corporate Bonds
The Federal Reserve announced on March 23, 2020 further action in response to the coronavirus crisis: the creation of the Secondary Market Corporate Credit Facility (SMCCF), along with establishment of the Primary Market Corporate Credit Facility (PMCCF) and the Term Asset-Backed Securities Loan Facility (TALF). We discuss the…
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Fed Establishes the Primary Market Corporate Credit Facility to Support Credit to Employers
The Federal Reserve announced on March 23, 2020 further action in response to the coronavirus crisis: the creation of the Primary Market Corporate Credit Facility (PMCCF), along with the Secondary Market Corporate Credit Facility (SMCCF) and the Term Asset-Backed Securities Loan Facility (TALF). We discuss the SMCCF and…
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Client Memorandum: FDIC Proposes Supervision of ILC Holding Companies
The FDIC proposed a rule to formalize certain longstanding expectations it has for approving applications by new industrial loan companies (ILCs) that would be subsidiaries of a parent company that would not be subject to consolidated supervision by the Federal Reserve. The proposal would require a written agreement…
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Davis Polk Client Memorandum: Agencies Extend Volcker Rule Relief for Qualifying Foreign Excluded Funds
As widely expected, the Volcker Agencies extended relief from the Volcker Rule that was first granted to eligible foreign funds in 2017. The agencies’ action provides that the proprietary trading and covered fund prohibitions of the Volcker Rule do not apply: (1) to a foreign banking entity for activities or…
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