Davis Polk submitted a comment letter to the Federal Reserve on its notice of proposed rulemaking to amend its regulatory framework for deciding when a company exercises a controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners’ Loan Act.  We
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Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Summer Spotlight Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and
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The Federal Reserve has requested comment on a highly anticipated notice of proposed rulemaking to amend its regulatory framework for deciding when a company exercises a controlling influence over another company under the Bank Holding Company Act and the Home Owners’ Loan Act.

The proposal is a welcome step in
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On Tuesday, April 30, our partner Margaret E. Tahyar will testify before the Senate Committee on Banking, Housing, and Urban Affairs at a public hearing regarding “Guidance, Supervisory Expectations, and the Rule of Law: How do the Banking Agencies Regulate and Supervise Institutions?”

Ms. Tahyar’s prepared testimony is available here
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The U.S. banking agencies have proposed allowing custodial banking organizations to exclude certain central bank deposits from the calculation of total leverage exposure, the denominator of the U.S. Basel III supplementary leverage ratio (SLR).  The proposal implements Section 402 of the Economic Growth, Regulatory Relief and Consumer Protection
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Tom Baxter of Sullivan & Cromwell LLP, and formerly the General Counsel of the Federal Reserve Bank of New York, has written an important article titled “The Rise of Risk Management in Financial Institutions and a Potential Unintended Consequence – The Diminution of the Legal Function,” recently published by the
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Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the New Congress Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and
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The Federal Reserve, FDIC and OCC (the Banking Agencies) recently published a proposal to increase the thresholds associated with the “major assets” prohibition governing management official interlocks contained in the Depository Institutions Management Interlocks Act (DIMIA)[1] and implemented by Regulation L.  DIMIA permits the Banking Agencies to raise the
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The Federal Reserve, FDIC and OCC (the Agencies) have each released proposed amendments to their respective stress testing rules for national banks, savings associations, state member banks and state non-member banks (collectively, IDIs) that would implement Section 401 of the Economic Growth, Regulatory Relief and Consumer Protection Act of 2018
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In the decade leading up to the 2008 financial crisis, de novo bank charters averaged more than 100 per year.[1] This robust flow of new bank charters continued a trend since the 1960s and before.[2] It partially offset a decline in the number of banks in the United
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