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FDIC Proposes Toughening CIDI Resolution Plan Rules

In Short - The Situation: The Federal Deposit Insurance Corporation ("FDIC") has proposed significant amendments (the "Proposal") to its rule requiring covered insured depository institutions ("CIDIs") to prepare and file...more

Federal Court Rejects CFPB's Novel Use of "Unfair, Deceptive, or Abusive Acts or Practices" Authority

Ruling concludes "unfairness" authority under the Dodd-Frank Act does not cover discrimination. On September 8, 2023, a federal district court rejected the Consumer Financial Protection Bureau's ("CFPB") interpretation...more

Federal Banking Agencies Propose Increased Capital Requirements for Large Banks

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

FSOC Proposals Renew Threat of Nonbank "Systemically Important" Designations

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

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