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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Bank Regulation
Recommended Read: The Rise of Risk Management in Financial Institutions and a Potential Unintended Consequence – The Diminution of the Legal Function and the Role of Legal Departments
By Margaret E. Tahyar on
Posted in Bank Regulation, Corporate Governance
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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Davis Polk Financial Services Regulatory Reform Tool—New Congress Edition
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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Board Interlocks and Investment in the Banking Sector—The Federal Banking Regulators Propose to Raise the Asset Thresholds
Posted in Bank Regulation, FDIC, Federal Reserve, Fintech, Management Interlocks, OCC, Proposed Rule
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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Federal Banking Regulators Propose EGRRCPA-Conforming Amendments to Stress Testing Rules
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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FDIC Pledges to Jump Start the De Novo Bank Approval Process
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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Visual Memorandum: A New Cut – Federal Reserve and U.S. Banking Agencies Propose Tailored Regulatory Framework
The move away from a one-size-fits-all regulatory framework based on asset size continues.
On October 31, the Federal Reserve proposed a rule to implement Section 401 of the Economic Growth, Regulatory Relief and Consumer Protection Act, tailoring enhanced prudential standards for firms with $100 billion or more in total consolidated…
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Resolution 2.0 – The Future of U.S. Resolution Planning for U.S. G-SIBs Starts to Come into Focus
The future of resolution planning for U.S. global systemically important banking organizations (G-SIBs) has started to come into focus. The FDIC and the Federal Reserve have recently laid out an ambitious agenda designed to put in place Resolution Planning 2.0. This slide sets forth our collection of the…
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Davis Polk Financial Services Regulatory Reform Tool—Post Midterm Election Edition
Posted in Administrative Law, Anti-Money Laundering, Bank Capital, Bank Regulation, CFPB, CFTC, Community Reinvestment Act, Cost-Benefit Analysis, Dodd-Frank, Economic Sanctions, FDIC, Federal Reserve, Fintech, FSOC, Legislation, Liquidity, OCC, OFAC, Stress Testing, Swap Regulation, TLAC, U.S. Basel III, U.S. Congress, Volcker Rule
Financial services regulatory reform will continue to evolve in 2018 and 2019. As we observe the changing legislative landscape, here is the Post Midterm Election 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…
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Visual Memorandum: The Federal Reserve’s Large Financial Institution Rating System — Final Rule
By The Davis Polk FIG Team on
The Federal Reserve has finalized a new supervisory ratings system for large financial institutions (LFIs), discussed in our visual memorandum here. The new LFI rating system, which reflects the three core areas of focus in the Federal Reserve’s current LFI supervisory framework—capital, liquidity and governance and controls—is…
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