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Last week, the US federal banking regulators proposed changes to the enhanced supplementary leverage ratio (“eSLR”) requirement for US global systemically important bank holding companies (“US GSIBs”) (the “Proposal”)....more
In light of ongoing litigation and the Trump administration’s new policy approach, federal banking agencies intend to rescind the 2023 CRA final rule and revert to pre-2023 standards....more
On February 7, Secretary of the Treasury Scott Bessent announced that he will appoint Rodney E. Hood as a Deputy Comptroller and designate him as the First Deputy Comptroller of the Office of the Comptroller of the Currency...more
Late last year, I wrote that the the Board of Directors of the Federal Deposit Insurance Corporation had voted unanimously to approve the staff’s request for authorization to file a suit against six former officers and 11...more
Through joint guidance and an information request, federal bank regulators underscored banks’ compliance responsibilities in their banking-as-a-service (BaaS) relationships with third parties. Our Financial Services Team...more
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed revisions to the restrictions on brokered deposits (the “Proposal”). The Proposal is intended to strengthen the restrictions to reflect the FDIC’s...more
The federal banking agencies have published joint guidance for banks about risks posed by fintech companies and other third parties to deliver bank deposit products and services. The joint guidance issued on July 30...more
On September 18, 2023, the U.S. Basel III Endgame proposal was published in the Federal Register. The comment period ended on January 16, 2024, with the banking regulators (the Federal Reserve, the OCC, and the FDIC) having...more
It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more
The SEC has issued a controversial 886-page final rule imposing climate-related disclosure requirements on publicly traded companies, including banking organizations, which will require them to include certain climate-related...more
Following the 2023 bank failures, the federal banking regulators (the Federal Reserve, the OCC, and the FDIC) have signaled that they are seeking to develop more stringent bank regulatory requirements for larger banking...more
On July 27, 2023, the Federal Reserve, FDIC, and OCC issued a notice of proposed rulemaking and request for comment on a proposal (the Proposal) to implement the final components of the Basel III Capital Accords, often...more
On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more
On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...more
After a tumultuous few days, Silicon Valley Bridge Bank, N.A. and Signature Bridge Bank, N.A. are open to deposit and loan customers. Early on Friday, March 10, 2023, bank regulators closed Silicon Valley Bank, the...more
The two banks’ sudden failure raises many questions about depositors’ ability to access accounts held at the banks when they closed. The following is intended to provide an overview of the current updates issued by the FDIC...more
Federal regulators took over Silicon Valley Bank after shutting it down on Friday – two days after SVB’s announcement that it had lost almost $2 billion in Treasury bonds. The bank, which caters to many of the world’s most...more
Secretary of the Treasury Janet L. Yellen, Federal Reserve Board Chair Jerome H. Powell, and Federal Deposit Insurance Corporation (FDIC) Chairman Martin J. Gruenberg issued a joint statement this evening approving actions...more
In the past year, the Board of Governors of the Federal Reserve System (the Board) Biden administration officials, and other U.S. banking regulators have repeatedly voiced growing concerns about certain cryptoasset...more
Federal Reserve Policy Aims to Level the Playing Field for Insured and Uninsured Banks: The Federal Reserve has issued a policy statement clarifying that uninsured state member banks will be subject to the same limitations...more
Banking organizations should ensure appropriate risk management, but regulators are skeptical of certain crypto activities as principal. On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal...more
On January 3, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together, the “federal banking regulators”) issued a joint...more
Banking regulators across the world often engage proactively with their chartered banks to provide guidance about their priorities. They want feedback, comment, and input about issues that may need addressing. This helps...more
It takes something significant for all the US Banking Regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – to come together to pool...more
Introduction - On November 18, federal banking agencies issued the long-awaited final rule, establishing data security incident response notification requirements for “banking organizations” and “bank service providers”...more