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U.S. federal banking regulators plan to revive efforts to regulate financial institution incentive compensation, as required under Section 956 of the Dodd–Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act).  The Wall Street Journal reports that the current effort is in its “early stages” and is being…
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As the new Congress gets underway, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations, confirmations, resignations and expiring terms.  The first slide summarizes the state of play for the agencies’ principals; the later slides provide a deeper look on…
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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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The Federal Reserve and FDIC (the Agencies) provided feedback on the U.S. resolution plans filed in July 2018 by four Foreign Banking Organizations – finding shortcomings in each, but acknowledging the need for more coordination among U.S. and home country regulators.  Unredacted copies of the letters sent on December…
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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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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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Davis Polk has submitted a comment letter on the FDIC’s Request for Information on FDIC Communication and Transparency.   Our comment letter concentrates on ways in which we believe that the FDIC could improve its website, with a particular focus on how the FDIC’s efforts could educate users and ameliorate…
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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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