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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On June 19, 2018, Margaret E. Tahyar will moderate the “Supervisory and Examination Issues and Updates” panel at the 2018 Prudential Regulation Conference hosted by SIFMA and The Clearing House in Washington, D.C.  In connection with Ms. Tahyar’s participation in this event, we are today releasing two interrelated visual memoranda
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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,
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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,


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On Halloween, the New York and Vermont attorneys general obtained a $700,000 settlement from Hilton for, among other violations, late breach notification.  Davis Polk has published a blog post on this increase in cyber regulation enforcement and the effect on breach notification deadlines.  The full blog post is available at
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The Federal Reserve’s proposed supervisory guidance on corporate governance is a breath of fresh air that should encourage banking boards to focus on their core responsibilities and avoid blurring the distinctions between executive and non-executive duties.  It is also a signal that supervisors intend to move away from the blunt
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The Federal Reserve has proposed changes to its guidance on corporate governance for banking organizations, which refocus its supervisory expectations more clearly on a board’s core responsibilities. The proposal distinguishes more clearly the roles and responsibilities of boards and senior management, eliminates redundant and outdated SR letters and guidance, and
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The Board of Governors of the Federal Reserve System (Federal Reserve) has proposed a new rating system for large financial institutions (LFIs). This proposal is intended to more closely align the Federal Reserve’s supervisory rating system with its supervisory program for LFIs.

LFIs are (i) bank holding companies and non-insurance,
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