The FDIC and the Federal Reserve Board have solicited public comment on the use of the Uniform Financial Institutions Rating System, more commonly known as CAMELS ratings. The release asks 10 questions, which focus on the ways in which the agencies use the CAMELS system, their consistency in doing so,
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Bank Regulation
It’s Time to Rebuild the Role of Bank Legal Departments
In an article in the ABA’s Business Law Today, partner Meg Tahyar expresses concern about a recent trend in which the role of banks’ legal staffs has been constrained and reduced as separate risk and compliance functions have grown in prominence. She says this is the opposite of the trend…
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Davis Polk Financial Services Regulatory Reform Tool—Fall Focus Edition
Financial services regulatory reform continues to evolve in 2019. As we observe the changing landscape, here is the Fall Focus 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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Davis Polk Comments on Federal Reserve’s Proposed Rule on Confidential Supervisory Information
Navigating the outdated rules on confidential supervisory information has become increasingly difficult in the digital world because the rules have their origin in the paper-based world of 1967, when they were first enacted. In the meantime, the amount and type of information made available by the banking agencies to banking…
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Davis Polk Comments on Federal Reserve’s Proposed Rule on Controlling Influence
By Luigi L. De Ghenghi & Randall D. Guynn on
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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Davis Polk Financial Services Regulatory Reform Tool—Summer Spotlight Edition
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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Public Memorandum | Federal Reserve’s Proposed Rule on Controlling Influence: A Step in the Right Direction
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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Davis Polk Partner to Testify before Senate Banking Committee about Bank Supervision and Regulation
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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U.S. Banking Agencies Propose Custody Bank Relief under the Supplementary Leverage Ratio
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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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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