Margaret E. Tahyar

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Ms. Tahyar is a partner in Davis Polk’s Financial Institutions Group. [Full Bio]

The Federal Reserve’s recent updates to its regulations on confidential supervisory information and availability of information under the Freedom of Information Act include several meaningful modifications to adapt these rules for the digital age of emails, data rooms and slide decks and the modern organizational structure and operations of banking…
Continue Reading 10 Key Takeaways from the Federal Reserve’s Final Rule on CSI and FOIA

As Acting Comptroller Brian Brooks promised in his Statement on Becoming Acting Comptroller, the OCC proposed a rule on July 20, 2020, setting forth standards for determining the true lender of a loan made in the context of a partnership between a national bank or federal savings association (…
Continue Reading The OCC Proposes Two Standards for the True Lender Question

Updated May 7, 2020

We have updated Davis Polk’s table summarizing the Federal Reserve’s actions to address the coronavirus crisis, with embedded links to the primary materials on the Federal Reserve’s website.

Visit Davis Polk’s Government Support for Businesses page for more information on these and other federal Continue Reading Fed Actions to Address the Coronavirus Crisis

The Federal Reserve has taken temporary measures (and has published FAQs) to (1) lift the net debit cap on and waive fees for daylight overdrafts for financially sound depository institutions, including U.S. branches and agencies of foreign banking organizations, and (2) provide a streamlined approval process for other depository…
Continue Reading Federal Reserve Eases Daylight Overdraft Limits

President Trump signed a $484 billion stimulus bill into law today as part of the U.S. government’s ongoing efforts to contain the economic damage from the COVID-19.  The bill passed the House of Representatives and the Senate earlier this week with broad bipartisan support.

The measure is designed to supplement…
Continue Reading SBA Paycheck Protection Program to Receive Additional Funding

Updated April 13, 2020

We have updated Davis Polk’s summary table of the Federal Reserve’s actions to address the coronavirus crisis, with embedded links to the primary materials on the Federal Reserve’s website.  This version is updated to cover the new, sweeping measures that the Fed announced on the morning…
Continue Reading Fed Actions to Address the Coronavirus Crisis

Congress passed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) this afternoon, and we cover it here in two memos. In one memo, we cover the economic stabilization, small business and bank regulatory sections of the legislation. In the other memo, we cover tax…
Continue Reading Congress Passes the CARES Act: Economic Stabilization and Tax Relief

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…
Continue Reading 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 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…
Continue Reading Fed Establishes the Primary Market Corporate Credit Facility to Support Credit to Employers

Here is Davis Polk’s two-page overview of the Federal Reserve’s actions to address the coronavirus crisis, with embedded links to the primary materials on the Federal Reserve’s website. This version is updated to cover the new, sweeping measures that the Fed announced on the morning of Monday, March 23, 2020.  …
Continue Reading Fed Actions to Address the Coronavirus Crisis