Financial services regulatory reform will continue to be active in 2021, with the Biden Administration focused on activity at the intersection of financial regulation and social policy.  As we observe the changing landscape, here is the Spring Forward Edition of our reference tool, which provides context and summarizes current and
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—Spring Forward Edition

Digital dollars and central bank digital currencies (CBDC) are in the spotlight, and questions abound as to the potential design, availability and functionality of a CBDC in the United States. This deck tracks U.S. congressional legislative efforts that may lead to the creation of a U.S. digital dollar,
Continue Reading Digital Dollars / Central Bank Digital Currencies

The Federal Reserve has finalized its supervisory guidance on board of directors’ effectiveness (Board Effectiveness Guidance) more than three years after it was proposed.  The final Board Effectiveness Guidance is a key milestone in the Federal Reserve’s multi-year review of the practices of boards of directors, particularly at
Continue Reading Federal Reserve Finalizes Board Effectiveness Guidance

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