Do Banks Still Need Holding Companies?
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
The U.S. Financial Stability Oversight Council issued a proposed decision with respect to a national bank’s petition to not treat the surviving entity of a bank holding company parent merging into its large U.S. national bank...more
On May 23, Congress passed a bill to revise Dodd-Frank to reduce regulatory burdens on banks. Just as with the original Dodd-Frank Act, the real work will have to be done by the banking agencies and thus months will have to...more
On March 4, 2016, the Board of Governors of the Federal Reserve System (the “Fed”) issued a Notice of Proposed Rulemaking (“NPRM”), inviting comment on reproposed rules (the “Reproposed Rules”) that would establish single...more
U.S. bank regulators recently adopted final rules establishing initial and variation margin requirements for uncleared swaps (Final Margin Rules). These rules apply to regulated entities such as banks and subsidiaries of bank...more
1. Question: What is the Volcker Rule, and when does it take effect? Answer: The Volcker Rule was enacted into law as section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank...more
The Federal Reserve Board approved a final rule requiring the largest, most systemically important U.S. bank holding companies to further strengthen their capital positions. Under the rule, a firm that is identified as a...more
The Enhanced Prudential Standards (Regulation YY) of the Board of Governors of the Federal Reserve System represent a significant shift in the U.S. regulation of foreign banking organizations (FBOs). In general, Regulation...more
On Wednesday, the House passed a bill that would further delay the full implementation of the Volcker Rule – a highly controversial rule introduced under the Dodd-Frank Wall Street Reform and Consumer Protection Act that...more
Overview This Client Alert continues Pepper’s observations on the Volcker Rule. Critical attention should be paid to the Volcker Rule’s anti-evasion provision, a powerful tool granted by Congress to the regulatory agencies to...more
The Federal Reserve Board Amends Stress Test Rules - On Friday, October 17, 2014, the Federal Reserve Board (the "Board") issued a final rule modifying the regulations for capital planning and stress testing and...more
On February 18, the Fed issued a final rule which establishes enhanced supervision standards for large U.S. bank holding companies and foreign banking organizations, as required by the Dodd-Frank Act. The final rule will be...more
On February 18, the Federal Reserve Board (Federal Reserve) approved a Final Rule to enhance supervision over the largest US bank holding companies (BHCs) and the largest foreign banking organizations (FBOs) with operations...more
On December 10, 2013, after more than three years of intensive development, the Board of Governors of the Federal Reserve System (FRB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation...more
On December 10, 2013, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Securities and Exchange Commission (collectively,...more