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

The Financial Stability Oversight Council’s (FSOC) recently revised guidelines (the 2019 Guidelines) on how it will identify and address financial stability risks are a major shift from the guidelines it issued in the immediate aftermath of the Financial Crisis.  The 2019 Guidelines draw upon lessons learned from
Continue Reading Client Memorandum: FSOC Shift to an Activities-Based Approach Signals an Emphasis on the Risks to Financial Stability from Digital Transformation

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 Davis Polk Financial Services Regulatory Reform Tool—Post Midterm Election Edition

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 Zions to Shed Its Holding Company – Will Others Follow?

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 Davis Polk Financial Services Regulatory Reform Tool—Fall Focus Edition

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,
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—Summer Beach Read Edition

Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and provide updated versions
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—May 2018

Financial services regulatory reform in 2018 is complex and evolving. To assist in navigating this landscape, we have prepared a reference tool that provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and provide updated versions
Continue Reading Davis Polk Financial Services Regulatory Reform Tool–March 2018

There are distinct, but subtle, shifts in tone in the FSOC’s 2017 Annual Report, especially when compared to previous annual reports and read together with three recent Treasury reports on financial regulatory reform, each of which touches on the role of the FSOC.[1] Taken as a whole, the 2017
Continue Reading FSOC 2017 Annual Report—A Subtle Shift in Tone that Signals the Possibility of Meaningful Change

The Trump Treasury Department’s vision for how the FSOC should fulfill its mission is emerging.[1]  Ironically, this new, and we think better vision, may be closer to how the Obama Treasury Department originally conceived the FSOC’s role.  In essence, we read the implicit Treasury viewpoint to be that the over-focus
Continue Reading Treasury’s Recommendation for FSOC: No CHOICE but to Play Double Duty