Davis Polk Insights on Financial Regulation
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…
Continue Reading
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…
Continue Reading
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…
Continue Reading
As we emerge from the midterm 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
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…
Continue Reading
FDIC Chairman Jelena McWilliams has announced a “Trust through Transparency” initiative that is remarkable and well worth a read. In our view, there are three main takeaways. One is the importance of transparency to public trust in a Democracy, the second is how important it is that the government be…
Continue Reading
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
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
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
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