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

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

The Federal Reserve announced an expansion of the Commercial Paper Funding Facility (CPFF), originally announced on March 17, 2020 as part of its response to the coronavirus crisis.  Under the expanded CPFF, “eligible issuers” now include municipal issuers—which had been excluded in the 2008 version of the CPFF—and
Continue Reading Fed Expands Commercial Paper Funding Facility to Cover Municipal Issuers and Decrease Pricing

The Senate Republicans recently released a proposal for Phase 3 of the government’s stimulus response to the coronavirus (COVID-19) emergency.  Our rush summary describes certain key portions of that proposal that we think will be of interest to our clients and friends. We cover the return of the money market
Continue Reading Senate Republicans Release a Stimulus Proposal to Combat Economic Impacts of Coronavirus

The FDIC has issued two new sets of FAQs, one for financial institutions and the other for consumers, that address issues that may arise with respect to customers and communities affected by the coronavirus.  The FDIC is encouraging financial institutions to work with customers especially borrowers from affected industries and
Continue Reading FDIC Issues FAQs for Financial Institutions and Consumers Affected by the Coronavirus

The FDIC proposed a rule to formalize certain longstanding expectations it has for approving applications by new industrial loan companies (ILCs) that would be subsidiaries of a parent company that would not be subject to consolidated supervision by the Federal Reserve. The proposal would require a written agreement
Continue Reading Client Memorandum: FDIC Proposes Supervision of ILC Holding Companies

  • The Federal Reserve’s announcement that it is creating a Commercial Paper Funding Facility (CPFF) is the Federal Reserve’s first use of its “unusual and exigent circumstances” powers in this crisis.[1]
  • It is designed to make sure that any U.S. issuer of commercial paper (CP), including


Continue Reading The Fed Moves to Shore Up Commercial Paper Markets

On January 30, 2020, the Federal Reserve Board, OCC, FDIC, SEC and CFTC (the Agencies) proposed amendments to the covered fund provisions of the Volcker Rule. The proposed amendments address long-standing concerns with the over-broad definition of covered fund, the treatment of foreign funds (both public and private), and the
Continue Reading Volcker 2.1: Agencies Propose Revisions to Covered Fund Provisions

In a welcome move, two recent actions by the Federal Reserve, OCC and FDIC (the Banking Agencies) recognize the increasing role of fund complexes and passive investing.  The Banking Agencies have released a statement under the Federal Reserve’s Regulation O which acknowledges the reality that equity mutual funds may sometimes
Continue Reading Federal Banking Agencies Recognize the Rise of Index Funds and Passive Investing

In a step forward for the digital transformation of banking and partnerships between banks and FinTechs, the FDIC released proposed changes to its brokered deposit regulations in late December 2019. The proposed changes are designed to update the regulatory framework as much as possible within the constraints of the existing
Continue Reading Encouraging Innovation: Brokered Deposits—What Fintechs Need to Know to Partner with Banks under the FDIC’s Proposed Regulations