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

On November 9, 2020, we released our deck “Financial Services Regulatory Reform in the Biden Administration: Key Areas of Focus.” This deck describes our view of the road ahead for financial regulatory reform under a Biden Presidency and a Republican Senate.  We see most of the action coming from the
Continue Reading Financial Services Regulatory Reform in the Biden Administration: Key Areas of Focus

The banking sector is both regulated and supervised, a key difference between banking and the rest of the regulated sectors in the economy.  Supervision happens behind the veil of confidential supervisory information in ways that are both appropriate and concerning.[1]  The scope of what is appropriate and what is
Continue Reading Federal Financial Regulatory Agencies Propose New Rule Clarifying the Role of Supervisory Guidance

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