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Regulators Finalize Amendments to the Swap Margin Rule and Seek to Extend Implementation Deadline

On June 25, 2020, the Federal Reserve, Farm Credit Administration, Federal Deposit Insurance Corporation, Federal Housing Finance Agency and Office of the Comptroller of the Currency (the “Agencies”) finalized amendments to...more

Navigating Systemic Risk: Protecting Financial Institutions form Avoidable Losses

COVID-19 has acted as an accelerator, bringing into play scenarios which were previously only contingencies and making contingencies of (and requiring planning for) situations which were previously barely imaginable. The debt...more

Federal Reserve Releases Stress Test Results: Restrictions on Share Repurchases and Dividends in Response to COVID-19

On June 25, 2020, the Federal Reserve Board (the “Fed”) released (i) the results of its supervisory stress tests for 2020; and (ii) aggregate, not bank-specific, results of a special “sensitivity analysis” conducted under a...more

NYDFS Adopts Forbearance Regulations for Regulated Institutions

The New York Department of Financial Services (“NYDFS”) promulgated regulations (“Part 119”) on March 24, 2020, to provide financial relief to individuals who can demonstrate a financial hardship as a result of the COVID-19...more

UPDATED - The Fed Repurposes the Financial Crisis Playbook for Pandemic Response

In the face of the coronavirus (COVID-19) pandemic, the U.S. Federal Reserve Board (the Fed) and the U.S. federal banking agencies have announced several market and supervisory actions to address the sudden market stress and...more

The Fed Repurposes the Financial Crisis Playbook for Pandemic Response

In the face of the coronavirus (“COVID-19”) pandemic, the U.S. Federal Reserve Board (the “Fed”) and the U.S. federal banking agencies have announced several market and supervisory actions to address the sudden market stress...more

Planning in a Time of Pandemic: Considerations for Regulated Financial Institutions in the US, EU and UK

The economic and operational stresses caused by the Novel Coronavirus (COVID-19) are highlighting the need for regulated financial institutions to formulate responses to address significant business disruptions (SBDs) and to...more

NYDFS Requires COVID-19 Preparedness Plans from Regulated Entities

The arrival of Novel Coronavirus (“COVID-19”) in New York, and the United States more generally, has roiled the U.S. and global economy and significantly affected numerous businesses. In light of these circumstances, the New...more

NYDFS Requires COVID-19 Preparedness Plans from Virtual Currency Businesses

The arrival of Novel Coronavirus (COVID-19) in New York, and the United States more generally, has roiled the U.S. and global economy and significantly affected numerous businesses. In light of these circumstances, the New...more

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