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

In the decade leading up to the 2008 financial crisis, de novo bank charters averaged more than 100 per year.[1] This robust flow of new bank charters continued a trend since the 1960s and before.[2] It partially offset a decline in the number of banks in the United
Continue Reading

The move away from a one-size-fits-all regulatory framework based on asset size continues.

On October 31, the Federal Reserve proposed a rule to implement Section 401 of the Economic Growth, Regulatory Relief and Consumer Protection Act, tailoring enhanced prudential standards for firms with $100 billion or more in total consolidated
Continue Reading

Davis Polk has submitted a comment letter on the FDIC’s Request for Information on FDIC Communication and Transparency.   Our comment letter concentrates on ways in which we believe that the FDIC could improve its website, with a particular focus on how the FDIC’s efforts could educate users and ameliorate
Continue Reading

The future of resolution planning for U.S. global systemically important banking organizations (G-SIBs) has started to come into focus.  The FDIC and the Federal Reserve have recently laid out an ambitious agenda designed to put in place Resolution Planning 2.0.  This slide sets forth our collection of the
Continue Reading

It is no secret that the United States lags behind other countries in the development of a national real-time payments infrastructure.[1]  There are, of course, explanations for this lag, including widespread participation in the existing infrastructure rails and the existence of many different stakeholder interests limiting consensus over reforms. 
Continue Reading

FDIC Chairman Jelena McWilliams has announced a “Trust through Transparency” initiative that is remarkable and well worth a read.  In our view, there are three main takeaways.  One is the importance of transparency to public trust in a Democracy, the second is how important it is that the government be
Continue Reading

This blog post lays out the pros and cons that boards and senior management of regional and community banking organizations should consider in light of the Zions decision to shed its bank holding company.[1]  Some have suggested that directors of BHCs now have a fiduciary duty to consider shedding
Continue Reading

Guidance is guidance, and rules are rules.  This straightforward statement was reiterated by Treasury Secretary Mnuchin, Federal Reserve Vice Chairman for Supervision Randal Quarles and Comptroller of the Currency Joseph Otting in separate Congressional hearings earlier this year.[1]  Nevertheless, for at least the past ten years, the failure to
Continue Reading

The FTC is expanding its enforcement efforts for fintech, particularly in the areas of online and small-business lending, payments, and cryptocurrencies.  At a recent event in Washington, D.C., the FTC’s Director of Consumer Protection, Andrew Smith, stated, “Commissioners are really interested in [fintech].  Finance will be a steady part of
Continue Reading

The Center for Financial Stability is providing a freely accessible Financial Timeline, curated by Senior Fellow Yubo Wang.  The timeline, created in 2010 and actively maintained, charts more than 1,100 developments across the markets, institutions, the Federal Reserve, Treasury and other sources, from 2007 to the present.  This resource, which
Continue Reading