Davis Polk Insights on Financial Regulation
Ms. Tahyar is a partner in Davis Polk’s Financial Institutions Group. [Full Bio]
The SBA has issued a long-awaited Procedural Notice providing guidance on the procedures for changes of ownership of an entity that has received Paycheck Protection Program funds.
Our memorandum contains flowcharts outlining when SBA consent is required for M&A transactions involving borrowers that want to sell their business to another…
Continue Reading SBA Guidance: M&A Transactions and PPP Borrowers
The OCC has issued an interpretive letter confirming that national banks may take deposits that serve as reserves for fiat currency-pegged stablecoins. The letter continues the series of actions taken or announced by Acting Comptroller Brian Brooks to clarify how traditional banking regulations apply to fintech activities—particularly when those activities…
Continue Reading OCC Confirms that National Banks May Take Deposits that Serve as Reserves for Fiat-Pegged Stablecoins
Our memo delivers key takeaways on the Federal Reserve’s recent announcement about its research into central bank digital currency, along with some useful resources. We also place the Federal Reserve’s recent announcement, in a speech by Governor Lael Brainard, in the overall international context.
Please read our client memorandum for…
Continue Reading The Federal Reserve And Central Bank Digital Currencies
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