Last week, Martin Gruenberg, Acting Chair of the Federal Deposit Insurance Corporation (“FDIC”), gave remarks at the Brookings Institution on the Prudential Regulation of Crypto-Assets....more
The Federal Deposit Insurance Corporation (“FDIC”) Board had a busy Tuesday. In addition to the release of an ANPR on Resolution Requirements for large banking organizations that we also write about this week, the FDIC Board...more
The Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) Board issued an Advanced Notice of Proposed Rulemaking (“ANPR”) titled “Resolution-Related Resource Requirements for Large Banking...more
10/20/2022
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Banks ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
FRB ,
Global Systemically Important Banks (G-SIBs) ,
Mergers ,
OCC ,
Regulatory Agenda
Last week, just after we went to press, the Office of the Comptroller of the Currency (“OCC”) released its Bank Supervision Operating Plan for Fiscal Year 2023.
The Operating Plan sets out the OCC’s supervision...more
Federal Reserve Board (“FRB”) Governor Michelle Bowman gave an important speech last week on the future of supervision and regulation at the Institute of International Finance....more
On September 28, Federal Reserve Board (“FRB”) Governor Michelle Bowman spoke to the Community Banking Research Conference regarding the landscape for banking competition. Governor Bowman noted, as many have, that it is past...more
On September 20, the White House announced President Biden’s intent to nominate two Republicans, Travis Hill and Jonathan McKernan, to the FDIC Board. It has also been reported that President Biden will nominate a permanent...more
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
Federal Reserve Vice Chair of Supervision Michael Barr gave remarks yesterday to the Brookings Institution in Washington, D.C. The speech was his first since being sworn in at the end of July and served as a good indicator of...more
The DOJ recently published an opinion from the Office of Legal Counsel (“OLC”) regarding the FDIC Board. The OLC opinion concluded that “the Chairperson of the FDIC Board does not have the authority to prevent a majority of...more
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
Last week, the Federal Reserve Board (“FRB”) announced the individual capital requirements for all large banks, effective on October 1. This announcement follows the June announcement on the results of the supervisory stress...more
Last week, the Federal Deposit Insurance Corporation (“FDIC”) was part of two releases clarifying that only insured banks and thrifts enjoy FDIC insurance, notwithstanding what some non-banks may say in their marketing...more
On July 25, the Federal Deposit Insurance Corporation (“FDIC”) announced amendments to its Enforcement Actions Manual. The amendments to chapters 1 and 4 update and clarify the FDIC’s approach to terminating cease-and-desist...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
Recently, the full Senate confirmed Michael Barr to a four-year term as Vice Chair for Supervision and to Randal Quarles’ unexpired term as a member of the Board of Governors. That unexpired term as a member of the Board will...more
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 July 11, 2022, the Alternative Reference Rates Committee (the “ARRC”) published a “Playbook” to assist market participants in transitioning their legacy LIBOR contracts to an alternative rate by June 30, 2023. The...more
On July 6, five federal agencies − the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Financial Crimes Enforcement Network (“FinCEN”), National Credit Union...more
The Office of the Comptroller of the Currency (“OCC”) issued its Semiannual Risk Perspective for Spring 2022 on June 23. This was the same day the Federal Reserve released the results of its stress test for large bank holding...more
On June 23, the Federal Reserve Board issued the aggregate and individual results of the supervisory stress test (also known as the Dodd-Frank Act Stress Test or DFAST, as these tests are required by Section 165 of the...more
By the time the comment period closed on June 17, 2022, the SEC had received thousands of comment letters from the public in response to the SEC’s proposed climate disclosure rules (the “Proposal”), which is perhaps the most...more
6/27/2022
/ American Bankers Association ,
Climate Change ,
Corporate Governance ,
Corporate Social Responsibility ,
CREFC ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Public Comment ,
Publicly-Traded Companies ,
Regulatory Agenda ,
Regulatory Reform ,
SEC Comment Letter Process ,
Securities and Exchange Commission (SEC)
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