The Federal Reserve, FDIC and OCC (the Agencies) have each released proposed amendments to their respective stress testing rules for national banks, savings associations, state member banks and state non-member banks (collectively, IDIs) that would implement Section 401 of the Economic Growth, Regulatory Relief and Consumer Protection Act of 2018
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Federal Reserve
Feedback on Foreign Banks’ July 2018 Resolution Plan Submissions – Key Takeaways
The Federal Reserve and FDIC (the Agencies) provided feedback on the U.S. resolution plans filed in July 2018 by four Foreign Banking Organizations – finding shortcomings in each, but acknowledging the need for more coordination among U.S. and home country regulators. Unredacted copies of the letters sent on December…
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Visual Memorandum: A New Cut – Federal Reserve and U.S. Banking Agencies Propose Tailored Regulatory Framework
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…
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Resolution 2.0 – The Future of U.S. Resolution Planning for U.S. G-SIBs Starts to Come into Focus
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…
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Status of Financial Regulatory Leadership Changes
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…
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Davis Polk Financial Services Regulatory Reform Tool—Post Midterm Election Edition
Posted in Administrative Law, Anti-Money Laundering, Bank Capital, Bank Regulation, CFPB, 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 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…
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Visual Memorandum: The Federal Reserve’s Large Financial Institution Rating System — Final Rule
By The Davis Polk FIG Team on
The Federal Reserve has finalized a new supervisory ratings system for large financial institutions (LFIs), discussed in our visual memorandum here. The new LFI rating system, which reflects the three core areas of focus in the Federal Reserve’s current LFI supervisory framework—capital, liquidity and governance and controls—is…
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A Breath of Fresh Air at the FDIC: The “Trust through Transparency” Initiative
By Randall D. Guynn & Margaret E. Tahyar on
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…
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Status of Financial Regulatory Leadership Changes
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…
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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…
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