Mr. De Ghenghi is a partner in Davis Polk’s Financial Institutions Group. [Full Bio]

The Federal Reserve and the OCC have proposed a rule that would recalibrate the enhanced supplementary leverage ratio (eSLR) requirements applicable to U.S. GSIBs and their insured depository institution (IDI) subsidiaries, and related requirements, by tailoring the eSLR levels to 50 percent of each firm’s GSIB surcharge.  The proposal would … Read More

The Stress Buffer Requirements (SBR) Proposal would fundamentally restructure how the Federal Reserve’s stress testing and capital planning framework is used to impose capital requirements for large banking organizations.  In general, the proposal would shift the quantitative capital requirements based on a firm’s pro forma stress losses, which currently are … Read More

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 … Read More

The Bipartisan Banking Bill would provide banking organizations with relief from their stress testing, capital and liquidity requirements by adjusting the thresholds, frequency and substance of these rules.  The bill – which recently passed in the Senate, as described in a recent post here – is now being considered in … Read More

The Senate has passed the Bipartisan Banking Bill, which would raise the generally applicable statutory threshold for most enhanced prudential standards (EPS) from $50 billion to $250 billion in total consolidated assets and would provide other targeted relief to regional and community banks.  It would also make a … Read More

Continuing the trend of Congressional attention to U.S. capital requirements for banking organizations, the United States House of Representatives has passed a bill that seeks to address the calculation of risk-weighted assets (RWAs) for operational risk under the U.S. Basel III capital rules (House Bill).  The … Read More

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, … Read More

Vice Chair for Supervision Randal Quarles’ announcement that the Federal Reserve is re-examining its framework for making control determinations under the Bank Holding Company Act is a welcome development.  In critiquing the control framework, which has developed piecemeal over decades, Vice Chair Quarles called it “complex and occasionally opaque” and … Read More

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, … Read More

The Financial Stability Board, Basel Committee on Banking Supervision, Committee on Payments and Market Infrastructures and International Organization of Securities Commissions announced late last week a survey focusing on the effects of post-crisis regulatory reforms on incentives to centrally clear over-the-counter (OTC) derivatives.

The G20 agreed in 2009 to promote … Read More