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Since the 2016 Second Circuit decision in Madden v. Midland Funding, LLC,[1] banks and their non-bank lending partners have faced legal uncertainty about their ability to assign or transfer loans.  The Madden decision and subsequent actions by state courts have called into question the “valid-when-made” doctrine, which stands…
Continue Reading U.S. Federal Banking Regulators Propose a Madden Fix

As we look forward to fall, 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 look on…
Continue Reading Status of Financial Regulatory Leadership Changes

Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, 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…
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—Fall Focus Edition

The U.S. banking agencies have released a final rule amending the U.S. Basel III capital rules to simplify the capital treatment of capital deductions and recognition of minority interests for non-advanced approaches banking organizations, as well as implementing certain technical amendments applicable to both advanced approaches and non-advanced approaches banking…
Continue Reading Davis Polk Client Memorandum: Banking Agencies Simplify Capital Rules for Non-Advanced Approaches Firms

As summer gets underway, 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 look on an agency-by-agency…
Continue Reading Status of Financial Regulatory Leadership Changes

Financial services regulatory reform continues to evolve in 2019.  As we observe the changing landscape, here is the Summer Spotlight 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…
Continue Reading Davis Polk Financial Services Regulatory Reform Tool—Summer Spotlight Edition

The U.S. banking agencies have proposed allowing custodial banking organizations to exclude certain central bank deposits from the calculation of total leverage exposure, the denominator of the U.S. Basel III supplementary leverage ratio (SLR).  The proposal implements Section 402 of the Economic Growth, Regulatory Relief and Consumer Protection…
Continue Reading U.S. Banking Agencies Propose Custody Bank Relief under the Supplementary Leverage Ratio

U.S. federal banking regulators plan to revive efforts to regulate financial institution incentive compensation, as required under Section 956 of the Dodd–Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act).  The Wall Street Journal reports that the current effort is in its “early stages” and is being…
Continue Reading Bank Pay Rules May Be Resurrected

As the new Congress gets underway, 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 look on…
Continue Reading Status of Financial Regulatory Leadership Changes