Davis Polk has submitted a comment letter on the Federal Reserve’s proposed supervisory guidance on board governance (which we summarized in a previous blog post). Consistent with our previous blog posts on the proposed board guidance and separate management guidance issued by the Federal Reserve for large financial institutions, … Read More
In his recent speech that we have covered in a series of blog posts, Federal Reserve Vice Chair for Supervision Randal Quarles announced that he would like the Federal Reserve to achieve “meaningful simplification of our framework of loss absorbency requirements,” referring to both the Federal Reserve’s capital and … Read More
The Mulvaney Memo on the CFPB and the rule of law is one of the most remarkable documents to be published by an agency head in many years. It signals a deep commitment to the rule of law as a philosophical concept and as an important brake on agency discretion … Read More
Vice Chair for Supervision Randal Quarles’ announcement that the Federal Reserve is re-examining its framework for making control determinations under the Bank Holding Company Act is a welcome development. In critiquing the control framework, which has developed piecemeal over decades, Vice Chair Quarles called it “complex and occasionally opaque” and … 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
In its first hearing of the year, the Senate Committee on Banking, Housing, and Urban Affairs expressed support for potential reforms to the U.S. anti-money laundering (“AML”) and countering the financing of terrorism (“CTF”) framework. The hearing focused on the relationships among financial institutions, regulators, and … 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
The Financial Stability Board, Basel Committee on Banking Supervision, Committee on Payments and Market Infrastructures and International Organization of Securities Commissions announced late last week a survey focusing on the effects of post-crisis regulatory reforms on incentives to centrally clear over-the-counter (OTC) derivatives.
The G20 agreed in 2009 to promote … Read More
In what we expect to be the first step in a process of increasing the transparency of the Federal Reserve’s supervisory stress tests and their application to banking organizations subject to the Dodd-Frank Act supervisory stress testing requirements and the Federal Reserve’s Comprehensive Capital Analysis and Review (CCAR) framework, the … Read More
Six years after finalizing the first set of Basel III reforms to the capital framework for banking organizations, the Basel Committee on Banking Supervision has agreed on and released the final set of revisions to the Basel III capital standards (sometimes referred to as “Basel IV”).
The reforms include the … Read More