Today, we released our deck “The Road Ahead for Financial Regulatory Reform in a Time of Democrats in Control.” This deck describes our view of the road ahead for financial regulatory reform under a Biden Presidency, and updates the deck we published shortly after the 2020 election to reflect the
Continue Reading The Road Ahead for Financial Regulatory Reform in a Time of Democrats in Control

On December 15, 2020, the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation issued a notice of proposed rulemaking that would require substantially faster notification of cybersecurity incidents involving banking organizations, expand the list of triggering events, and impose first-of-its kind
Continue Reading Banking Agencies Propose Cyber Reporting Rule: Implications for Cybersecurity Compliance

On November 9, 2020, we released our deck “Financial Services Regulatory Reform in the Biden Administration: Key Areas of Focus.” This deck describes our view of the road ahead for financial regulatory reform under a Biden Presidency and a Republican Senate.  We see most of the action coming from the
Continue Reading Financial Services Regulatory Reform in the Biden Administration: Key Areas of Focus

Last week the Board of Governors of the Federal Reserve System (the Federal Reserve) announced changes to the terms of the Main Street Lending Program (the Program) aimed at boosting small business participation in the Program. As explained in further detail below, the Federal Reserve reduced the minimum
Continue Reading Federal Reserve Board Amends the Terms of the Main Street Lending Program to Support Small Businesses

The Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board (together the Agencies) last week proposed amendments (the Proposed Rules) to the Travel Rule regulations and related Recordkeeping Rules under the Bank Secrecy Act (together the Rules).[1]

Lowering the threshold for cross-border transfers
Continue Reading FinCEN and the Federal Reserve Board Propose Travel Rule Amendments to Lower the Threshold for Cross-Border Transfers and to Explicitly Cover Convertible Virtual Currencies and Digital Money

The banking sector is both regulated and supervised, a key difference between banking and the rest of the regulated sectors in the economy.  Supervision happens behind the veil of confidential supervisory information in ways that are both appropriate and concerning.[1]  The scope of what is appropriate and what is
Continue Reading Federal Financial Regulatory Agencies Propose New Rule Clarifying the Role of Supervisory Guidance

The Federal Reserve has opened the Main Street Lending Program to nonprofits. Main Street loans are complicated, and the fact that Main Street’s nonprofit lending facilities were bolted onto an existing framework for profit-driven corporations adds another layer of complexity. We hope this memo helps clarify the program and serves
Continue Reading Main Street Support for Nonprofits

Our memo delivers key takeaways on the Federal Reserve’s recent announcement about its research into central bank digital currency, along with some useful resources. We also place the Federal Reserve’s recent announcement, in a speech by Governor Lael Brainard, in the overall international context.

Please read our client memorandum for
Continue Reading The Federal Reserve And Central Bank Digital Currencies

The Federal Reserve’s recent updates to its regulations on confidential supervisory information and availability of information under the Freedom of Information Act include several meaningful modifications to adapt these rules for the digital age of emails, data rooms and slide decks and the modern organizational structure and operations of banking
Continue Reading 10 Key Takeaways from the Federal Reserve’s Final Rule on CSI and FOIA

We have updated our visual memo on the Main Street Program and our memo on the legal architecture of the Main Street Program to reflect the expansion of the program and the revised program documents that the Federal Reserve announced this week. The visual memo provides an overview of the
Continue Reading Main Street Program: Updated Davis Polk Memos