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

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

In what we expect to be the first step in a process of increasing the transparency of the Federal Reserve’s supervisory stress tests and their application to banking organizations subject to the Dodd-Frank Act supervisory stress testing requirements and the Federal Reserve’s Comprehensive Capital Analysis and Review (CCAR) framework, the … Read More

Six years after finalizing the first set of Basel III reforms to the capital framework for banking organizations, the Basel Committee on Banking Supervision has agreed on and released the final set of revisions to the Basel III capital standards (sometimes referred to as “Basel IV”).

The reforms include the … Read More

The Senate’s bipartisan regulatory relief bill advanced out of the Senate Banking Committee this week with only minor changes and remains on a path to a filibuster-proof majority.  The bill would provide regulatory relief to regional, community and custody banks, among others—as described in two earlier posts here and hereRead More

The Federal Reserve Board announced today that it will continue its policy of not deploying the countercyclical buffer (CCyB), a decision it reached after assessing the considerations in its September 2016 CCyB policy statement and consulting with the FDIC and OCC.

The CCyB is a macroprudential policy tool that the … Read More

Does the bipartisan Senate bill described in our earlier post leave large banks, i.e., banking organizations with $250 billion or more in total consolidated assets, and foreign banking organizations (FBOs) entirely out in the cold?  No, but the relief it provides to large banking organizations is quite limited, and it … Read More

The U.S. banking agencies (the Federal Reserve, OCC and FDIC) have delayed the last phase of the U.S. Basel III capital rules’ transition provisions relating to certain deductions from capital and limitations on the recognition of minority interests, which were scheduled to become effective January 1, 2018, for banking organizations … Read More