While the Trump Administration’s approach to bank regulation has been the subject of much speculation, specific proposals have yet to emerge, and the administration has yet to name key personnel in the regulatory agencies. ...more
Three federal regulators have reproposed rules that implement the requirements for bank incentive compensation programs that were included in the Dodd-Frank legislation 14 years ago. Section 956 of Dodd-Frank required the...more
The Federal Reserve Board (“FRB”) Inspector General (the “OIG”) has issued a highly critical report regarding FRB supervision of Silicon Valley Bank (“SVB”) in the years preceding the bank’s failure in March 2023. The...more
The Federal Reserve Board (the “FRB”) has signaled a new approach to the oversight of “novel” activities by banks subject to FRB supervision. In a recent letter to supervisory staff, the FRB indicated that it would introduce...more
A periodic review of regulatory enforcement actions is a useful guide to what not to do in the financial services sector. This post focuses on several recent enforcement actions – one by the Federal Reserve Board (the...more
A toxic combination of poor risk management and poor regulatory supervision proved fatal for Silicon Valley Bank (“SVB”) and Signature Bank (“Signature”), according to a series of reports released on April 28, 2023 by federal...more
The Federal Reserve Board (the “Board”) has adopted amendments to the Board’s regulatory capital framework (“Regulation Q”), that clarify how the revised regulatory capital framework applies to depository institution holding...more