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Interview with Ethan Heisler of the Bank Treasury Newsletter

Matt Bisanz interviews Ethan Heisler, founder of the Bank Treasury Newsletter, on recent developments in bank funding risk....more

Some US Regulators Repropose Joint Rule on Incentive-Based Compensation

On May 6, 2024, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Federal Housing Finance Agency (FHFA) and National Credit Union Administration (NCUA; collectively the...more

To Infinity and Beyond: FinCEN Announces Access Rule Schedule

On April 18, 2024, the Financial Crimes Enforcement Network (“FinCEN”) announced its revised implementation schedule for providing access to the beneficial ownership information (“BOI”) reports. The tentative, revised...more

Implications of an Early Extension of a 364-day Credit Facility

Because banks receive favorable capital treatment when a credit facility’s tenor is shorter than one year, lenders increasingly offer financing with 364-day tenors and uncommitted extension option terms of up to 364 days. In...more

How Many Digits? FinCEN Seeks Comment on Bank Customer Identification Requirements

On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more

Interview with Isaac Boltansky from BTIG

Matt Bisanz interviews Isaac Boltansky, Director of Policy Research at BTIG, about the risks and regulatory trends for the rest of the year....more

What to Expect in Banking in 2024

The end of 2023 saw a barrage of major proposals and other actions by US banking regulators. Many of these are contentious issues that have divided regulators and generated significant public controversy. Final proposals of...more

FinCEN Proposes New Residential Real Estate Reporting Requirements

On February 7, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking on certain US residential real estate transactions (“2024 NPRM”). The 2024 NPRM...more

Time Warp? Proposed Basel Endgame Reporting Requirements Released Before Final Rule

On January 26, 2024, the US federal banking regulators announced proposed reporting changes to implement the Basel III Endgame requirements. This may come as a surprise to the many banking organizations and others, who only...more

Private Credit Reporting Requirements Proposed by US Banking Regulators

On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more

NYDFS Finalizes Climate Risk Management Guidance

On December 21, 2023, the New York Department of Financial Services (“NYDFS”) finalized guidance on how the banks and mortgage institutions it regulates (“New York Institutions”) should manage climate-related financial and...more

Fund Finance Reporting Requirements Proposed by US Banking Regulators

On December 27, 2023, the US federal banking regulators proposed reporting requirements for bank loans and commitments to the fund finance sector. This change reflects not only the rapid growth in this sector but also the...more

FinCEN Issues Final Rule About Accessing Beneficial Ownership Information

On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) released a final rule to implement the beneficial ownership information (“BOI”) access requirements of the Corporate Transparency Act (“CTA”) (the...more

Cart Before Horse: Banking Regulators Extend Comment Period and Launch Data Collection for Basel Endgame

On October 20, 2023, the US federal banking regulators announced that they were extending the period for public comment to January 16, 2024 for both the (i) Basel Endgame proposal to significantly revise the risk-based...more

Overhaul of Regulatory Capital Requirements Proposed by US Banking Regulators

On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and...more

Basel Committee Seeks Public Comments on Bank Supervision

On July 6, 2023, the Basel Committee on Banking Supervision (“Basel Committee”) released proposed revisions to its core principles for effective banking supervision (the “Revised Principles”). The Revised Principles are...more

Residential Mortgage Loans: Capital Relief Through Synthetic Securitization

Banking organizations looking to reduce the amount of risk-based regulatory capital required to support residential mortgage loan portfolios can use synthetic securitization to convert the capital treatment of their exposures...more

Biden Executive Order Calls for Regulatory Proposals on Digital Assets and Central Bank Digital Currency

On March 9, 2022, President Biden signed an executive order titled “Ensuring Responsible Development of Digital Assets” (the “Order”).1 The Order directs a broad range of federal agencies to recommend legislative and...more

US Financial Regulators Release Much-Anticipated Report on Stablecoins

On November 1, 2021, the President’s Working Group on Financial Markets (PWG) released its much-anticipated Report on Stablecoins (Report). The Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of...more

Potential Volcker Rule Changes Announced

On January 30, 2020, five federal financial regulatory agencies published the long awaited notice of proposed rulemaking (the “NPR”) to revise certain aspects of the Volcker Rule (Section 13 of the Bank Holding Company Act)...more

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