Mr. Johansen is an associate in Davis Polk’s Financial Institutions Group. [Full Bio]

Davis Polk has submitted a comment letter on the Federal Reserve’s proposed amendments to its guidelines on internal appeals of material supervisory determinations (the Proposal).  While we understand, of course, that discretion is a necessary element of supervision, our concern is with discretion that is insufficiently accountable, involves legal … Read More

Continuing the trend of Congressional attention to U.S. capital requirements for banking organizations, the United States House of Representatives has passed a bill that seeks to address the calculation of risk-weighted assets (RWAs) for operational risk under the U.S. Basel III capital rules (House Bill).  The … Read More

Federal Reserve Vice Chair for Supervision Randal Quarles recently sought to answer the question that he has been asked most frequently since assuming his post three months ago: What’s next? He expressed his support for the reforms that have made the financial system stronger and more resilient since the Financial … Read More

The CFPB’s announcement of a call for evidence is a welcome sign that the new leadership of the agency is thinking seriously about how it implements its mission. In the coming weeks the CFPB will publish a series of Requests for Information (RFIs) seeking public comment on the CFPB’s enforcement, … Read More

The Federal Reserve’s proposed core principles on management of large financial institutions are another welcome addition to its efforts to clarify and better distinguish between the roles of boards of directors and the management of large financial institutions. The new guidance (Management Guidance) describes core principles of effective senior management, … Read More