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

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 a further expansion of the Money Market Mutual Fund Liquidity Facility (MMLF), originally announced on March 18, 2020 and expanded on March 20, 2020, as part of its response to the coronavirus crisis.  Under the further expanded MMLF, additional securities are eligible as collateral.
Continue Reading Fed Further Expands Money Market Mutual Fund Liquidity Facility to Include Municipal Variable Rate Demand Notes and Bank CDs

The Federal Reserve has created a new secured liquidity facility, called the Term Asset-Backed Securities Loan Facility (TALF), designed to restore liquidity to the asset-backed securities (ABS) market.  TALF represents a continuation of the Federal Reserve’s use of its “unusual and exigent” powers to help provide
Continue Reading Fed Establishes a Term Asset-Backed Securities Loan Facility

The Federal Reserve announced an expansion of the Money Market Mutual Fund Liquidity Facility (MMLF) originally announced on March 18, 2020 as part of its response to the coronavirus crisis.  Under the expanded MMLF, certain municipal bonds are eligible as collateral and certain municipal MMFs are eligible for
Continue Reading Fed Expands Money Market Mutual Fund Liquidity Facility to Include Municipal Bonds

The Federal Reserve’s creation of a Money Market Mutual Fund Liquidity Facility (MMLF) follows the announcement of a Commercial Paper Funding Facility and a Primary Dealer Credit Facility, both of which we discussed earlier this week (link to CPFF memo, link to PDCF memo), and represents
Continue Reading Fed Establishes a Money Market Mutual Fund Liquidity Facility

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

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 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

The Financial Stability Oversight Council’s (FSOC) recently revised guidelines (the 2019 Guidelines) on how it will identify and address financial stability risks are a major shift from the guidelines it issued in the immediate aftermath of the Financial Crisis.  The 2019 Guidelines draw upon lessons learned from
Continue Reading Client Memorandum: FSOC Shift to an Activities-Based Approach Signals an Emphasis on the Risks to Financial Stability from Digital Transformation

The U.S. banking agencies have completed one of the most important steps towards rebalancing the U.S. bank regulatory framework since the Dodd-Frank Act was passed in the wake of the 2007 – 2008 financial crisis.  The agencies have adopted final rules to tailor enhanced prudential standards and U.S. Basel III
Continue Reading Visual Memorandum: Final Tailoring Rules for U.S. Banking Organizations