As we reported in May, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a notice of proposed...more
9/19/2022
/ Community Development ,
Community Reinvestment Act ,
Environmental Justice ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lending ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Redlining ,
Rulemaking Process
As we previously wrote in June, the Federal Deposit Insurance Corporation (“FDIC”) proposed amendments to the Deposit Insurance Fund (“DIF”) restoration plan originally adopted in September 2020 to implement a universal...more
This week, the Federal Reserve Board (“FRB”) made two announcements of particular interest to the crypto-asset sector. First, on August 15, the FRB announced its final guidelines establishing factors for Reserve Banks to use...more
On July 19, Federal Reserve Board (“FRB”) Vice Chair Lael Brainard gave remarks to the National Native Coalition Virtual Series sponsored by the National Congress of American Indians. Her remarks focused on the joint proposal...more
7/26/2022
/ Banks ,
Comment Period ,
Community Reinvestment Act ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
FRB ,
Investment ,
Native American Issues ,
OCC ,
Rural Development ,
Tribal Lands
The last week has seen a number of announcements or statements from financial regulators calling for more oversight of crypto-assets, particularly stablecoins.
Federal Reserve Vice Chair Lael Brainard gave a speech,...more
7/15/2022
/ Cryptoassets ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Federal Reserve ,
Financial Markets ,
Financial Regulatory Reform ,
Financial Services Industry ,
FSB ,
IOSCO ,
Regulatory Agenda ,
Stablecoins
On June 21, the Federal Deposit Insurance Corporation (“FDIC”) Board voted to amend the Deposit Insurance Fund (“DIF”) restoration plan originally adopted in September 2020. As part of that amended restoration plan, the FDIC...more
Over the last 18 months, we’ve seen a sharp uptick in inquiries from U.S. banks about how to use capital relief trades to manage regulatory capital constraints. Here, we set out our responses to some of the frequently asked...more
On June 15, the Basel Committee on Banking Supervision (“BCBS”) issued its Principles for the effective management and supervision of climate-related financial risks (the “Principles”). In its release, the BCBS stated that it...more
On May 17, the Federal Deposit Insurance Corporation (“FDIC”) issued Financial Institutions Letter 22-2022 updating the FDIC’s Guidelines for Appeals of Material Supervisory Determinations. The revised Guidelines restore the...more
As we mentioned briefly in our newsletter last week, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, “The Agencies”)...more
5/17/2022
/ Banking Regulators ,
Comment Period ,
Community Reinvestment Act ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
FRB ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Proposed Rules ,
Regulatory Agenda
On May 5, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a notice of proposed rulemaking to...more
5/9/2022
/ Banks ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Products ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FRB ,
NPRM ,
OCC ,
Regulatory Agenda ,
Regulatory Requirements
Last week the FDIC announced it will publish in the Federal Register a Request for Information and Comment (“RFI”) on the regulatory framework regarding mergers involving one or more insured depository institutions (i.e.,...more
On March 8, the Federal Register published the Federal Reserve Board’s supplemental notice and request for comment on updates to its proposed guidelines for Federal Reserve Banks to utilize in evaluating requests for access...more
I. Introduction -
As we note in our companion memorandum, the Office of the Comptroller of the Currency (“OCC”) continues along its cautious course of allowing fintech and digital asset firms into the so-called...more
On October 21, 2021, the Financial Stability Oversight Council (“FSOC”), established in 2010 by the Dodd-Frank Wall Street Reform and Consumer Protection Act to respond to emerging threats to the stability of the U.S....more
10/25/2021
/ Banking Sector ,
Climate Action Plan ,
Climate Change ,
Critical Infrastructure Sectors ,
Dodd-Frank ,
Environmental Justice ,
Environmental Social & Governance (ESG) ,
Financial Institutions ,
Financial Regulatory Reform ,
FSOC ,
Regulatory Oversight ,
Risk Controls ,
Risk Mitigation ,
Threat Management
On June 30, 2021, President Biden signed a joint resolution of Congress under the Congressional Review Act (“CRA”) to disapprove the OCC’s True Lender Rule. As a result, the True Lender Rule is now repealed....more
On May 11, the Senate voted 52-47 (with three Republicans joining 49 Democrats) to pass a joint resolution under the Congressional Review Act (“CRA”) to disapprove of (i.e., rescind) the Office of Comptroller of the...more