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Directive 2024/1619 (CRD VI) will (among other things) establish a new and more prescriptive EU regulatory regime for EU branches of non-EU banks. New harmonised licencing, authorisation, capital, liquidity, booking, and...more
The Bank of England (BoE) has published a suite of publications in its capacity as the UK′s resolution authority, covering significant updates in relation to its approach to setting the minimum requirement for own funds and...more
The UK Prudential Regulation Authority (PRA) has published its final policy statement in relation to amendments being made to the UK framework on capital buffers. Together with the Capital Buffers and Macro-prudential...more
The Single Resolution Board (SRB) has published updated operational guidance, accompanied by a press release, on the solvent wind-down (SWD) of trading books. The guidance is intended to outline the scope and key expectations...more
On June 27, the Federal Reserve Board issued the aggregate and individual results of the supervisory stress test (also known as the Dodd-Frank Act Stress Test or DFAST, as these tests are required by Section 165 of the...more
On June 27, the Fed released the results of its annual supervisory stress test, evaluating how large banks would perform under hypothetical adverse economic conditions. The Fed conducts stress tests annually as part of its...more
With a focus on pragmatic and risk-based oversight, new leadership at the Federal Reserve signals a shift in the regulatory landscape for U.S. banks. Earlier this month, the Senate confirmed Federal Reserve Governor Michelle...more
On an aggregate basis, banking industry net revenue improved in Q1 despite flattish NIM on near-record non-interest income and expense improvements....more
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 Federal Reserve Board has requested comment on a proposal designed to reduce the volatility of the capital requirements stemming from its annual stress tests. The proposal would achieve this primarily by averaging the...more
The Bank of England (BoE) has updated its stress testing webpage, announcing it has published two stress test scenarios for use by banks and building societies that are not participants in its concurrent stress testing...more
The European Banking Authority (EBA) has published its 2024 Reports on the annual market and credit risk benchmarking exercises. Both reports are mandated by Article 78 of the Capital Requirements Directive to assist...more
On March 28, the Fed released a report titled “Outlining and Measuring the Benefits of Risk Sensitivity in Bank Capital Requirements” evaluating the integration of risk regarding bank capital requirements. The report asserted...more
The European Commission (EC) has launched a consultation to help determine the best approach for the application of the EU's framework on market risk prudential requirements for banks, with an accompanying press release. Last...more
The Bank of England (BoE) has launched the 2025 bank capital stress test for the seven largest and most systemic UK banks and building societies. The exercise is the successor to the Annual Cyclical Scenario. The test...more
As the new administration settles in, it has begun to catalyze significant changes in the bank supervisory and regulatory environment. The FDIC is the first mover in this effort. Longtime director and sometime Chairman Martin...more
The Basel Committee on Banking Supervision has published a document on the finalization of various technical amendments to the Basel framework. The amendments relate to: (i) the definition of specialized lending in the...more
As a lending lawyer for more than a quarter century at this point, I have seen that deposit accounts and deposit account control agreements are a routine component of virtually every transaction. Deposit accounts are a source...more
Recently, the Fed released the 2024 Federal Reserve Stress Test Results and found that the tested banks have “sufficient capital” to absorb losses and weather a recession while staying above minimum capital requirements. The...more
Larger banking organizations directly affected by the U.S. federal banking agencies' recent proposed capital rule have been busy analyzing the substantial changes, increased costs, and other requirements and effects that have...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, in an effort to bolster the resilience of the U.S. banking system in the aftermath of recent bank failures and to promote consistency with international banking capital standards, the Federal Deposit...more
On July 27, the FDIC’s Board of Directors unveiled proposed interagency amendments to the regulatory capital requirements for the largest and most complex banks in the United States. The notice of proposed rulemaking (NPRM),...more
On July 10, Federal Reserve Board Vice Chair for Supervision Michael S. Barr delivered remarks at the Bipartisan Policy Center outlining proposed updates to capital standards. As part of his holistic review of capital...more
In the second installment of our video series aimed at helping borrowers in uncertain times, Matt Cheek, chair of Williams Mullen’s Financial Services Industry Group, and Mike Mueller, chair of our Restructuring, Bankruptcy...more