This second installment in a series of insights on bank charter considerations describes the consequences of operating through an insured depository institution charter, including capital requirements, supervision and...more
CFPB Announces Intention to Expand Enforcement Against Unfair Discrimination - The CFPB has published an updated examination manual for evaluating unfair, deceptive, and abusive acts and practices (“UDAAPs”), which explains...more
Section 13 of the Bank Holding Company Act of 1956 (the BHC Act) generally prohibits any insured depository institution (as defined in Section 3(c) of the Federal Deposit Insurance Act, but excluding institutions that...more
The proposed modifications, if adopted, would amend the Volcker Rule in a manner consistent with the statutory amendments under the Economic Growth, Regulatory Relief, and Consumer Protection Act. The Economic Growth,...more
Introduction - This practice note provides an overview of the Volcker Rule, which was enacted in 2010 as Section 619 of the comprehensive Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) and...more
In its March 2017 approval of People United Financial, Inc.’s merger with Suffolk Bancorp (the “Peoples United Order”), the Federal Reserve Board eased the approval criteria for certain smaller bank merger transactions by...more
Five federal agencies have taken a second stab at a proposed rule to establish margin requirements for swap dealers, major swap participants, security-based swap dealers, and major security-based swap participants as...more
The high profile insider trading trial of Matthew Martoma moved forward in New York this week with testimony on behalf of the prosecution. The SEC and four other agencies joined in granting relief from a provision of the...more
Since the release of the proposed rule to implement the Volcker Rule (the Proposed Rule) more than two years ago, participants in the financial services industry have continued to express concern about the burden of complying...more
The Federal Reserve Board, the OCC, the FDIC, the SEC and the CFTC (collectively, the “Agencies”) adopted an interim final rule (the “Interim Rule”) that provides relief from certain requirements of the Volcker rule for...more
On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Securities and Exchange Commission, and the Commodity Futures...more
On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the Commodity Futures Trading...more
On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Securities and Exchange Commission and the Commodity Futures...more
It took almost 3½ years before it finally hatched. And it was big—very big—enormous, in fact. No, it’s not Godzilla. It’s the Volcker Rule. More than two years after the Notice of Proposed Rulemaking, a final rule...more
The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission (the "SEC") issued a final rule, and the Commodity Futures...more