The Situation: On September 17, 2024, the Federal Deposit Insurance Corporation ("FDIC") approved a proposed rule ("the Proposal") that would establish new recordkeeping requirements for FDIC-insured depository institutions...more
The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more
2/15/2024
/ Bank Merger Act ,
Banks ,
BSA/AML ,
Community Reinvestment Act ,
Department of Justice (DOJ) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Global Systemically Important Banks (G-SIBs) ,
Merger Agreements ,
Merger Reviews ,
OCC ,
Policy Statement ,
Proposed Rules
The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...more
1/11/2024
/ Banks ,
Climate Change ,
FDIC ,
Federal Reserve ,
Final Guidance ,
Financial Institutions ,
Financial Services Industry ,
Joint Statements ,
OCC ,
Risk Management ,
Supervisory Guidance
The September 2023 publication by the U.S. Treasury Department of its Principles for Net-Zero Financing and Investment ("Principles") marks the first time a major U.S. government agency has provided guidance to the financial...more
12/4/2023
/ Banks ,
Climate Action Plan ,
Climate Change ,
Environmental Policies ,
Financial Institutions ,
Financial Regulatory Reform ,
Financing ,
Greenhouse Gas Emissions ,
Infrastructure ,
Investment ,
Net Zero ,
U.S. Treasury
In Short:
The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more
10/19/2023
/ Banks ,
Borrowers ,
Debt ,
Debt Collection ,
Debt Instruments ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Global Systemically Important Banks (G-SIBs) ,
Lenders ,
OCC ,
Proposed Rules ,
Subsidiaries
In Short -
The Situation: The federal banking agencies approved a proposal that would implement a "gold-plated" U.S. version of the "Basel III endgame."...more
In Short -
The Situation: The Financial Stability Oversight Council ("FSOC") recently issued a "notification of proposed interpretive guidance" on updated procedures for designating nonbank financial companies as...more
In Short -
The Background: The recent failure of Silicon Valley Bank, the second-largest bank failure in U.S. history, temporarily paralyzed start-ups, public companies, venture firms, private equity firms, and portfolio...more
First introduced following the 2008 global financial crisis, the Fundamental Review of the Trading Book (FRTB) was designed to establish worldwide rules pertaining to banks’ regulatory capital requirements as they apply to...more
In Short -
The Situation: The Federal Reserve Board ("Board") has issued a new policy statement ("Policy Statement") imposing limits, including Board approval requirements, on digital asset activities and other novel...more
On September 29, 2022, the Board of Governors of the Federal Reserve System ("Fed") announced that six of the largest U.S. banks will participate in a first-of-its-kind climate scenario analysis program. The Fed will provide...more