Our visual memorandum here describes the key changes the Bipartisan Banking Act makes to the regulation of banking organizations. It is color coded for those who want to look only at the changes that affect their own organization.

The House is expected to pass the Economic Growth, Regulatory Relief and … Read More

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 … Read More

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 … Read More

The Senate passed the Economic Growth, Regulatory Relief and Consumer Protection Act (S.2155) on March 14 by a filibuster-proof vote of 67 – 31.  The Senate bill still must pass the House, where Rep. Jeb Hensarling (R-TX) and other representatives have said they plan to propose a series of amendments … Read More

Buried in the latest Treasury Report, the third in a series, are important gems on the Volcker Rule and on the concept of controlling influence.[1]  Of the three interesting new recommendations, two are limited to the covered funds portion of the Volcker Rule and build upon the recommendations in the … Read More

The Office of the Comptroller of the Currency (the “OCC”) took a first formal step in evaluating how the regulations implementing the Volcker Rule should be revised by issuing a request for public input on the regulations in early August, with comments due in late September.  Of the 55 comment … Read More

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 … Read More

Guidelines on covered fund seeding extensions from the Federal Reserve yesterday, following on the heels of last Friday’s guidance for foreign excluded funds, is a hopeful sign that the freeze on Volcker Rule guidance is finally thawing.  Perhaps these green shoots signal that broader, common sense relief is coming.  Yesterday’s … Read More

Ever since the final Volcker Rule regulations were made public in December 2013, foreign banks and their regulators have expressed concern about the extraterritorial reach of the Volcker Rule to certain foreign funds that have a foreign bank as sponsor or investor.  This policy issue has, as is often the … Read More