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Final Climate Risk Guidance Ensures Supervisory Focus from Banking Agencies in 2024

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

What About the Kitchen Sink? FSOC Plans Even More in 2024

In Short - The Situation: Over the course of 2023, the Financial Stability Oversight Council ("FSOC") took steps that increase the risk of nonbank financial companies and financial activities being designated as...more

Federal Banking Agencies Propose Long-Term Debt Requirements for Large Banks

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

U.S. Federal Reserve Announces Climate Scenario Analysis Program

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

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