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
Introduction - As we approach the final quarter of 2020, we thought it would be helpful to recap one of the significant rule changes of the past few months that is likely to benefit venture capital funds and startup...more
Federal Regulators Ease Restrictions on Volcker Rule Covered Funds The federal banking agencies, along with the SEC and the CFTC, have issued a final rule to amend the regulations that implement Section 13 of the Bank...more
The federal agencies responsible for the Volcker Rule have proposed to clarify some requirements for exclusion from the definition of “covered fund” and to increase the types of funds excluded from that definition. The...more
In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more
Last week the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity Futures...more
On January 30, 2020, the U.S. Securities and Exchange Commission (SEC), the Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (“Fed”), the Federal Deposit...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
As of the end of August 2018, two key provisions of The Economic Growth, Regulatory Relief, and Consumer Protection Act (aka the Crapo bill, S.2155, or increasingly, EGRRCPA) have become effective: the increase in the small...more
Proposed Changes Subject to 60-Day Comment Period - On May 30, the Federal Reserve Board of Governors voted unanimously in favor of a proposal to amend section 13 of the Bank Holding Company Act (Volcker Rule), which was...more
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 codified as the new...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
On September 8, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Office of the Comptroller of the Currency (the “OCC,” and...more
Federal Reserve Announces Extension of Conformance Period under Section 13 of the Bank Holding Company Act - On July 7, 2016, the Federal Reserve announced that it will extend until July 21, 2017 the conformance period...more
On July 7, 2016, the Federal Reserve announced that it will extend until July 21, 2017 the conformance period for banking entities to divest ownership in certain legacy investment funds and terminate relationships with funds...more
The SEC first proposed a study of the fiduciary obligations of brokers and investment advisers as required by the Dodd-Frank Act in July 2010. The SEC still has not made a decision about the shape of a fiduciary 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
On December 10, 2013, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, and the Commodity...more