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Financial Institutions FRB Banks

Troutman Pepper Locke

The Federal Reserve’s Shift in Supervision Strategy for Novel Activities

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On August 15, the Federal Reserve Board announced a significant shift in its approach to supervising novel activities within banking organizations. The Board decided to sunset its Novel Activities Supervision Program, which...more

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

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The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

Mayer Brown

Federal Reserve Wins Two Master Account Lawsuits

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At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more

Cadwalader, Wickersham & Taft LLP

Trends in 2024: American Bar Association Banking Law Committee Insights

From January 18th to 20th, the American Bar Association’s Banking Law Committee of the Business Law Section held its winter meeting in Washington, DC. This meeting not only provides an excellent retrospective of the previous...more

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Liquidity Risk Management and Preparation for Use of Discount Window

Last Friday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the ECB Forum on Banking Supervision in Frankfurt, Germany entitled The Importance of Effective Liquidity Risk...more

Troutman Pepper Locke

FSOC Votes Unanimously to Finalize Process for Designating Nonbanks for Federal Reserve Supervision

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On November 3, the Financial Stability Oversight Council (FSOC) voted unanimously to finalize the procedures for designating a nonbank financial company for Federal Reserve supervision. FSOC’s Interpretive Guidance aims to...more

Cadwalader, Wickersham & Taft LLP

Federal Banking Agencies Finalize Community Reinvestment Act Rules

On Tuesday, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a final rule to amend and update...more

Cadwalader, Wickersham & Taft LLP

FRB Governor Bowman Speaks on Financial Stability

Last week, Federal Reserve Board (“FRB”) Governor Michelle Bowman gave a speech entitled Financial Stability in Uncertain Times, focusing on the “financial stability risks and vulnerabilities” she is most focused on....more

Cadwalader, Wickersham & Taft LLP

Financial Kaleidoscope October 2023 - Fed Issues FAQs Clarifying That Credit-Linked Notes Can Serve as Valid Capital Relief Tools...

On September 28, the Federal Reserve Board (“FRB”) posted three new FAQs to its website regarding Regulation Q (Capital Adequacy of Bank Holding Companies, Savings and Loan Holding Companies, and State Member Banks). The FAQ...more

Cadwalader, Wickersham & Taft LLP

Industry Trades Really Don’t Like the Basel III Endgame Proposal

As we covered previously, on July 27, 2023, the U.S. prudential bank regulators (the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”)...more

Cadwalader, Wickersham & Taft LLP

The Three Federal Banking Agencies Propose Long-Term Debt Requirement for All Large Banking Organizations

The Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a proposed rule (the “LTD NPR”) to require large banks...more

Ballard Spahr LLP

Federal Reserve Board issues letters on program to supervise novel banking activities

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Earlier this month, the Federal Reserve Board (FRB) released two supervision and regulation letters regarding the agency’s program to supervise “novel” banking activities....more

Latham & Watkins LLP

FRB Clarifies Supervision of Digital Assets and Bank-Fintech Partnerships

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A new program addresses innovative banking activities such as bank-fintech partnerships and digital assets while reinforcing guardrails around stablecoin activity. On August 8, 2023, the Board of Governors of the Federal...more

Cadwalader, Wickersham & Taft LLP

Banking Agencies Finalize Interagency Guidance on Third-Party Risk Management

On June 6, the three Federal bank regulatory agencies (the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)), issued final interagency...more

Latham & Watkins LLP

White House Recommends Stricter Regulations for Large Regional Banks

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President Biden is calling for tougher standards and supervision for large regional banks in the wake of recent instability in the US banking sector. On March 30, 2023, the White House issued a Fact Sheet calling on the...more

Cadwalader, Wickersham & Taft LLP

Congressional Hearings Calling Federal Regulators to Task for Recent Bank Failures

Both the Senate Banking Committee and House Financial Services Committee held hearings this week on the federal regulatory response to the failures of Silicon Valley Bank (“SVB”) and Signature Bank. Witnesses at both hearings...more

Cadwalader, Wickersham & Taft LLP

FRB Governor Bowman Speaks on Bank Regulation and Supervision

Federal Reserve Board (“FRB”) Governor Michelle Bowman gave remarks last week to the American Bankers Association (“ABA”) Community Banking Conference. Governor Bowman discussed the role of FRB independence, predictability...more

Cadwalader, Wickersham & Taft LLP

FRB and OCC Release 2023 Stress Test Scenarios

The Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) last week released their 2023 Dodd-Frank Act Stress Test (“DFAST”) scenarios. As noted in the FRB’s release, the “stress tests help...more

Orrick, Herrington & Sutcliffe LLP

Agencies release hypothetical scenarios for 2023 bank stress tests

On February 9, the Federal Reserve Board and the OCC released hypothetical economic scenarios for use in the upcoming stress tests for covered institutions. The Fed released supervisory scenarios, which include baseline and...more

Cadwalader, Wickersham & Taft LLP

FRB Issues Policy Statement on Permissible Activities of State Member Banks While Denying Uninsured Crypto-focused Bank’s...

The Federal Reserve Board (“FRB” or “Board”) issued two seemingly related press releases late last week. The first announced the denial of the Federal Reserve membership application by Custodia Bank, a Wyoming special purpose...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Announces Pilot Climate Scenario Analysis Exercise Details

Last week, the Federal Reserve Board (FRB) announced additional details on its pilot climate scenario analysis (CSA) involving six of the largest U.S. banks. The additional details include a Participant Instructions Document...more

Cadwalader, Wickersham & Taft LLP

FRB Chair Powell Speaks on Central Bank Independence

Federal Reserve Board (“FRB”) Chair Jerome Powell spoke at a symposium hosted by the Swedish Central Bank on Tuesday. In his speech, Chair Powell highlighted three main points: (1) that Federal Reserve monetary policy...more

Cadwalader, Wickersham & Taft LLP

Fed Will Not Be a “Climate Policymaker” According to Chair

The Chair of the U.S. Federal Reserve Board (Fed), Jerome Powell, stated in a speech at the Swedish Central Bank’s symposium on January 10 that the Fed is not a “climate policymaker." He stated that it was critical for the...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Issues Final Rule Implementing LIBOR Act

On December 16, 2022, the Board of Governors of the Federal Reserve System (the “Board”) adopted a final rule (the “Final Rule”) to implement the Adjustable Interest Rate (LIBOR) Act (the “LIBOR Act”).  The Final Rule follows...more

Cadwalader, Wickersham & Taft LLP

FRB Proposes Climate-Related Financial Risk Management Principles

Recently, the Federal Reserve Board (“FRB”) proposed principles for climate-related financial risk management for large financial institutions. The proposed guidance is open for comment until 60 days after publication in the...more

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