The Federal Reserve, OCC, FDIC, SEC and CFTC adopted final amendments on July 9, 2019 implementing the small-bank exclusion and name-sharing provisions of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final amendments modify the definition of “insured depository institution” and also permit a covered
Continue Reading Davis Polk Client Memorandum: Volcker Agencies Implement Small-Bank Exclusion and Name-Sharing Provisions of EGRRCPA

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 Resolution 2.0 – The Future of U.S. Resolution Planning for U.S. G-SIBs Starts to Come into Focus

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 The Federal Reserve Takes a Small Step toward a National Faster Payments Infrastructure

The Financial Stability Board (FSB) has a long history of taking the high road in proposing international financial regulatory standards.  Its Key Attributes for Effective Resolution Regimes for Financial Institutions is an excellent example.  That document established high standards for national laws governing the resolution of systemically important financial institutions
Continue Reading FSB Finalizes Guiding Principles on Internal TLAC

There is no shortage of ideas from the financial sector on how to rebalance financial sector regulation judging by the many reports, white papers and letters that have been sent to Treasury Secretary Mnuchin and his staff. We thought our readers, and perhaps the Treasury staff who must be burning
Continue Reading What We are Reading – Letters to the Treasury Secretary and His Staff