As we head into the mid-term election season, 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
Continue Reading
FDIC
Zions to Shed Its Holding Company – Will Others Follow?
This blog post lays out the pros and cons that boards and senior management of regional and community banking organizations should consider in light of the Zions decision to shed its bank holding company.[1] Some have suggested that directors of BHCs now have a fiduciary duty to consider shedding…
Continue Reading
Davis Polk Financial Services Regulatory Reform Tool—Fall Focus Edition
Posted in Administrative Law, Anti-Money Laundering, Bank Capital, Bank Regulation, BCFP, 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 in 2018 continues to evolve. As we leave summer behind, 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 will…
Continue Reading
Interagency Statement on Supervisory Guidance Could Result in Meaningful Changes to Supervisory Practices
Guidance is guidance, and rules are rules. This straightforward statement was reiterated by Treasury Secretary Mnuchin, Federal Reserve Vice Chairman for Supervision Randal Quarles and Comptroller of the Currency Joseph Otting in separate Congressional hearings earlier this year.[1] Nevertheless, for at least the past ten years, the failure to…
Continue Reading
Federal Banking Regulators Can and Should Resolve Madden and True Lender Developments
The ability of banks to sell the loans they originate is a core element in the development and sustainability of a nationwide lending market. Recent legal developments threaten to undermine this ability, jeopardizing the foundation of a U.S. nationwide loan market and the core lending activities of banks.
A long-settled…
Continue Reading
Release of Public Sections of 2018 IDI Plans and Foreign Filers’ 2018 165(d) Plans
By The Davis Polk FIG Team on
Today, the Federal Reserve and FDIC released the public sections of the 2018 165(d) resolution plans of Barclays, Credit Suisse, Deutsche Bank and UBS, which were due on July 1, 2018. The plans contain strategies for the rapid and orderly resolution of each firm’s U.S. operations under the Bankruptcy Code…
Continue Reading
Status of Financial Regulatory Leadership Changes
By Paul E. Means on
As we head into the July 4th holiday and the heart of summer approaches, we have updated our brief deck summarizing the leadership and staffing changes among federal financial regulators, including announced nominations, resignations and expiring terms. The first slide summarizes the state of play for the agencies’ principals;…
Continue Reading
Davis Polk Financial Services Regulatory Reform Tool—Summer Beach Read Edition
Posted in Administrative Law, Anti-Money Laundering, Bank Capital, Bank Regulation, BCFP, CFTC, Community Reinvestment Act, Cost-Benefit Analysis, Dodd-Frank, Economic Sanctions, FDIC, Federal Reserve, FSOC, Legislation, Liquidity, OCC, OFAC, Stress Testing, Swap Regulation, TLAC, U.S. Basel III, U.S. Congress, Volcker Rule
Financial services regulatory reform in 2018 continues to evolve. For those of you who have been thinking you might catch up over the summer lull, here is the summer beach read edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas,…
Continue Reading
Federal Reserve and FDIC Issue Proposed Guidance on U.S. G-SIBs’ 2019 Resolution Plan Submissions
By The Davis Polk FIG Team on
Today, the Federal Reserve and FDIC issued and invited comments on proposed guidance on the 2019 and subsequent submissions of the U.S. G-SIBs’ 165(d) resolution plans. The Proposed Guidance is available here.
The Proposed Guidance is largely similar to the guidance issued by the Agencies in April 2016, with…
Continue Reading
Federal Banking Agencies’ New Policy on Coordinating Enforcement Actions Is an Important First Step
Not enough attention has been paid to the FFIEC’s policy announcement on enforcement which is, we hope, the first step toward fundamental change. The Policy Statement on Interagency Notification of Formal Enforcement Actions rescinds a 1997 policy statement and addresses the need for coordination in enforcement actions among the Board…
Continue Reading