Proposed Rule

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On June 19, 2018, Margaret E. Tahyar will moderate the “Supervisory and Examination Issues and Updates” panel at the 2018 Prudential Regulation Conference hosted by SIFMA and The Clearing House in Washington, D.C.  In connection with Ms. Tahyar’s participation in this event, we are today releasing two interrelated visual memoranda…
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Our visual memorandum here describes the proposed amendments to the Volcker Rule regulations issued by the Federal Reserve, FDIC, OCC, SEC and CFTC, as well as key requests for comment about possible additional amendments. To make the analysis more user-friendly, the memorandum incorporates elements of Davis Polk’s flowcharts on the…
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Davis Polk has submitted a comment letter on the Federal Reserve’s proposed amendments to its guidelines on internal appeals of material supervisory determinations (the Proposal).  While we understand, of course, that discretion is a necessary element of supervision, our concern is with discretion that is insufficiently accountable, involves legal…
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The Federal Reserve and the OCC have proposed a rule that would recalibrate the enhanced supplementary leverage ratio (eSLR) requirements applicable to U.S. GSIBs and their insured depository institution (IDI) subsidiaries, and related requirements, by tailoring the eSLR levels to 50 percent of each firm’s GSIB surcharge.  The proposal would…
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The Stress Buffer Requirements (SBR) Proposal would fundamentally restructure how the Federal Reserve’s stress testing and capital planning framework is used to impose capital requirements for large banking organizations.  In general, the proposal would shift the quantitative capital requirements based on a firm’s pro forma stress losses, which currently are…
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In the first major trading and markets initiative under SEC Chairman Jay Clayton, on March 14, 2018, the SEC proposed to establish a transaction fee pilot program to study the effects of maker-taker fee structures. A pilot study was initially recommended by the SEC’s Equity Market Structure Advisory Committee in…
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After being one of the first countries to recognize blockchain technology in the field of cash vouchers, or minibons, France has become the first country to authorize the registration and transfer of unlisted securities by using the blockchain technology.

With the aim of making France the world’s forerunner in the…
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Among the virtual currency transactions that are within the scope of CFTC regulation are leveraged, margined, or financed transactions in virtual currencies offered to retail customers. These retail commodity transactions are illegal unless traded on a regulated futures exchange and cleared through a futures commission merchant. They include any transaction:…
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The U.S. banking agencies (the Federal Reserve, OCC and FDIC) propose to delay the last phase of the U.S. Basel III capital rules’ transition provisions relating to certain deductions from capital and limitations on the recognition of minority interests, which are scheduled to become effective January 1, 2018, for banking…
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