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

In the run up to the August recess, the Senate confirmed 76 of President Trump’s nominees last week, including a handful of senior personnel at various financial regulatory agencies. As we continue to track personnel changes at these agencies, we have updated our brief deck summarizing the leadership and staffing
Continue Reading Flurry of Confirmations Heading into the August Recess

The Office of the Comptroller of the Currency (OCC) issued a Notice today requesting public comment on potential changes to the regulations implementing the Volcker Rule. The Notice focuses on four topics, though makes clear that the OCC invites comments on all aspects of the Volcker Rule regulations and their
Continue Reading OCC Seeks Input on Volcker Regulation Reforms

There has been a slow start to financial regulatory reform under the Trump Administration, but the conversation is now changing in ways that are serious and thoughtful. This note highlights the key themes that we believe are important for mid-sized and regional banks in light of recent personnel announcements,
Continue Reading Regulatory Reform for Mid-Sized and Regional Banks: Where Are We at Mid-Year?

There is a world of difference between the initial public perceptions and the actual text of the executive order. The elegantly written Executive Order, sets forth a series of core principles that the Trump Administration believes should guide financial regulation. These principles are broad goals upon which, in more
Continue Reading The President’s Executive Order on Financial Regulation – A Thoughtful Step ForwardHidden Beneath the Spin

Today, the House of Representatives passed, by a 254-161 vote, the Systemic Risk Designation Improvement Act of 2016 (the “Act”), which is designed to relieve regional and specialty banking organizations from enhanced prudential standards and heightened supervision requirements under the Dodd-Frank Act. The Act would, after a one-year phase-in period,
Continue Reading The Systemic Risk Designation Improvement Act of 2016: A Different Approach to Regulatory Relief for Regional and Specialty Banking Organizations

President-Elect Trump’s transition website promises to “dismantle the Dodd-Frank Act and replace it with new policies to encourage economic growth and job creation.”  To help our clients keep up with the reorientation of the financial regulatory framework, Davis Polk is launching a new blog,

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Continue Reading Trump Transition: Financial CHOICE Act – Only the Beginning