The U.S. financial services industry continues to be faced with changes in technology – machine learning, database capabilities, automated process, and innovative products – that change the manner, speed and security with which financial services and products can be provided. Those of us familiar with the longer term evolution of … Read More
The Federal Reserve’s current approach to determining whether a banking organization has control over another company for purposes of the Bank Holding Company Act can discourage fintech investments by banking organizations. This impact was discussed in the Treasury Department’s report on nonbank financial institutions, fintech and innovation. The report highlights … Read More
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 … Read More
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; … Read More
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, … Read More
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 … Read More
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 … Read More
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 … Read More
The Federal Reserve held an open meeting today at which it released a proposal to modify the Volcker Rule regulations. Comments on the proposal will be due 60 days after the “date of issuance.” The other four regulators tasked with jointly implementing the Volcker Rule regulations are expected to release … Read More
Our visual memorandum here describes the key changes the Bipartisan Banking Act makes to the regulation of banking organizations. It is color coded for those who want to look only at the changes that affect their own organization.
The House is expected to pass the Economic Growth, Regulatory Relief and … Read More