Mr. Guynn is a partner and head of Davis Polk’s Financial Institutions Group. [Full Bio]

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

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

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

The Federal Reserve yesterday announced the opening of the registration process, and issued registration instructions and revised FAQs, for its Commercial Paper Funding Facility (CPFF), originally announced on March 17, 2020, expanded on March 23, 2020 and further detailed in initial FAQs on March 25, 2020. 
Continue Reading Fed Opens Registration Process for Commercial Paper Funding Facility

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 has issued updated FAQs regarding its money market mutual fund liquidity facility (MMLF), modifying the FAQs issued on March 21.

For more information on the MMLF, please see our memorandum and blog post describing the original MMLF announced on March 18, our blog post describing
Continue Reading Fed Updates FAQs for the Money Market Mutual Fund Liquidity Facility

The Federal Reserve has issued FAQs providing more information about its Commercial Paper Funding Facility (CPFF), originally announced on March 17, 2020 and expanded on March 23, 2020 as part of its response to the coronavirus crisis.  The FAQs provide additional details on how the CPFF will work,
Continue Reading Fed Issues FAQs for Commercial Paper Funding Facility