In its first hearing of the year, the Senate Committee on Banking, Housing, and Urban Affairs expressed support for potential reforms to the U.S. anti-money laundering (“AML”) and countering the financing of terrorism (“CTF”) framework.  The hearing focused on the relationships among financial institutions, regulators, and … Read More

The Senate’s bipartisan regulatory relief bill advanced out of the Senate Banking Committee this week with only minor changes and remains on a path to a filibuster-proof majority.  The bill would provide regulatory relief to regional, community and custody banks, among others—as described in two earlier posts here and hereRead More

Does the bipartisan Senate bill described in our earlier post leave large banks, i.e., banking organizations with $250 billion or more in total consolidated assets, and foreign banking organizations (FBOs) entirely out in the cold?  No, but the relief it provides to large banking organizations is quite limited, and it … Read More

The bipartisan Senate bill would open the door to welcome relief for regional and community bank holding companies (BHCs) by raising the statutory threshold for enhanced prudential standards from $50 billion to $250 billion in total consolidated assets.  The bill, titled the Economic Growth, Regulatory Relief and Consumer Protection ActRead More

The Leveraged Lending Guidelines are in an uncomfortable state of limbo.  After the GAO ruling that the Guidelines are a “rule” under the Congressional Review Act, they are no longer effective as guidance, but the silence from the OCC, the Federal Reserve, and the FDIC has been deafening.[1] The uncertainty … Read More

Many have commented on the suit filed last week challenging the CFPB’s arbitration rule, but few have considered what impact, if any, the suit could have on the fast-approaching compliance date of March 19, 2018.

As a reminder, the Chamber of Commerce and other trade associations filed a long-anticipated suit … Read More

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 … Read More

On August 2, 2017, President Trump signed into law the Countering America’s Adversaries Through Sanctions Act of 2017 (the “Act”).  The measure, which was passed by substantial bipartisan majorities in the House and in the Senate, codifies certain sanctions previously imposed by Executive Order (“E.O.”), provides for new sanctions with … Read More

After several weeks of negotiations between the House and the Senate, on July 25, the House passed by an overwhelming margin (419-3, with 12 members not voting) the Countering America’s Adversaries Through Sanctions Act, which would enact new economic sanctions measures against Iran, Russia, and North Korea and curtail the … Read More

The recent Treasury Report on financial regulatory reforms related to banks and credit unions devotes significant attention to issues of capital, stress testing and liquidity, which highlights the central role of these issues in the ongoing reform efforts.  The Treasury Report is, however, only a starting point; it makes recommendations … Read More