A lot of ink has been spilled in the last 72 hours regarding the historic developments involving Silicon Valley Bank and Signature Bank. Our quick summary of the facts and law is below. Cadwalader will continue to monitor...more
Earlier yesterday, the Federal Reserve Board (âFRBâ), Federal Deposit Insurance Corporation (âFDICâ) and Office of the Comptroller of the Currency (âOCCâ) issued a âJoint Statement on Liquidity Risks to Banking Organizations...more
2/24/2023
/ Banks ,
Cryptoassets ,
Cryptocurrency ,
FDIC ,
Federal Reserve ,
FRB ,
Joint Statements ,
Liquidity ,
Liquidity Risk Management Rule ,
OCC ,
Policy Statement
On December 22, just before many of us may have started turning to our holiday breaks, the Federal Reserve Board (âFRBâ), Federal Deposit Insurance Corporation (âFDICâ) and Office of the Comptroller of the Currency (âOCCâ)...more
1/12/2023
/ Banking Sector ,
Depository Institutions ,
Enforcement Actions ,
Enforcement Guidance ,
FDIC ,
Financial Services Industry ,
FRB ,
Interagency Guidance ,
No-Action Relief ,
OCC ,
Regulation O ,
Shareholders
As we are coming to a close on 2022, weâre taking a look back at some of the important developments of 2022 and what lies ahead for 2023.
Looking Back at 2022 -
As past readers may have seen me say before, thereâs a...more
Last week, the Federal Reserve Board (âFRBâ) and the Federal Deposit Insurance Corporation (âFDICâ) released their feedback to the eight global systemically important banking institutions (âG-SIBsâ) headquartered in the...more
Martin Gruenberg, Acting Chair of the Federal Deposit Insurance Corporation, gave remarks this week to the National Association of Affordable Housing Lenders (âNAAHLâ).
In the speech, Acting Chair Gruenberg praised NAAHLâs...more
Last week, Martin Gruenberg, Acting Chair of the Federal Deposit Insurance Corporation (âFDICâ), gave remarks at the Brookings Institution on the Prudential Regulation of Crypto-Assets....more
The Federal Deposit Insurance Corporation (âFDICâ) Board had a busy Tuesday. In addition to the release of an ANPR on Resolution Requirements for large banking organizations that we also write about this week, the FDIC Board...more
The Federal Reserve Board (âFRBâ) and Federal Deposit Insurance Corporation (âFDICâ) Board issued an Advanced Notice of Proposed Rulemaking (âANPRâ) titled âResolution-Related Resource Requirements for Large Banking...more
10/20/2022
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Banks ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
FRB ,
Global Systemically Important Banks (G-SIBs) ,
Mergers ,
OCC ,
Regulatory Agenda
On September 20, the White House announced President Bidenâs intent to nominate two Republicans, Travis Hill and Jonathan McKernan, to the FDIC Board. It has also been reported that President Biden will nominate a permanent...more
As we reported in May, the Federal Deposit Insurance Corporation (âFDICâ), the Federal Reserve Board (âFRBâ) and the Office of the Comptroller of the Currency (âOCCâ) (together, the âAgenciesâ) issued a notice of proposed...more
9/19/2022
/ Community Development ,
Community Reinvestment Act ,
Environmental Justice ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lending ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Redlining ,
Rulemaking Process
The DOJ recently published an opinion from the Office of Legal Counsel (âOLCâ) regarding the FDIC Board. The OLC opinion concluded that âthe Chairperson of the FDIC Board does not have the authority to prevent a majority of...more
As we previously wrote in June, the Federal Deposit Insurance Corporation (âFDICâ) proposed amendments to the Deposit Insurance Fund (âDIFâ) restoration plan originally adopted in September 2020 to implement a universal...more
Last week, the Federal Deposit Insurance Corporation (âFDICâ) was part of two releases clarifying that only insured banks and thrifts enjoy FDIC insurance, notwithstanding what some non-banks may say in their marketing...more
On July 25, the Federal Deposit Insurance Corporation (âFDICâ) announced amendments to its Enforcement Actions Manual. The amendments to chapters 1 and 4 update and clarify the FDICâs approach to terminating cease-and-desist...more
On July 19, Federal Reserve Board (âFRBâ) Vice Chair Lael Brainard gave remarks to the National Native Coalition Virtual Series sponsored by the National Congress of American Indians. Her remarks focused on the joint proposal...more
7/26/2022
/ Banks ,
Comment Period ,
Community Reinvestment Act ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
FRB ,
Investment ,
Native American Issues ,
OCC ,
Rural Development ,
Tribal Lands
On July 6, five federal agencies â the Board of Governors of the Federal Reserve System (âFRBâ), Federal Deposit Insurance Corporation (âFDICâ), Financial Crimes Enforcement Network (âFinCENâ), National Credit Union...more
On June 21, the Federal Deposit Insurance Corporation (âFDICâ) Board voted to amend the Deposit Insurance Fund (âDIFâ) restoration plan originally adopted in September 2020. As part of that amended restoration plan, the FDIC...more
On May 17, the Federal Deposit Insurance Corporation (âFDICâ) issued Financial Institutions Letter 22-2022 updating the FDICâs Guidelines for Appeals of Material Supervisory Determinations. The revised Guidelines restore the...more
As we mentioned briefly in our newsletter last week, the Federal Deposit Insurance Corporation (âFDICâ), the Federal Reserve Board (âFRBâ)Â and the Office of the Comptroller of the Currency (âOCCâ) (together, âThe Agenciesâ)...more
5/17/2022
/ Banking Regulators ,
Comment Period ,
Community Reinvestment Act ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
FRB ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Proposed Rules ,
Regulatory Agenda
On May 5, the Federal Deposit Insurance Corporation (âFDICâ), the Federal Reserve Board (âFRBâ) and the Office of the Comptroller of the Currency (âOCCâ) (together, the âAgenciesâ) issued a notice of proposed rulemaking to...more
5/9/2022
/ Banks ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Products ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FRB ,
NPRM ,
OCC ,
Regulatory Agenda ,
Regulatory Requirements
Last week, the FDIC issued a Financial Institution Letter (âFILâ) related to crypto activities, following in some ways in the footsteps of the OCC in requiring notice to the regulator before engaging in crypto-related...more
Last week the FDIC announced it will publish in the Federal Register a Request for Information and Comment (âRFIâ) on the regulatory framework regarding mergers involving one or more insured depository institutions (i.e.,...more
On March 22, the Federal Reserve Board issued a Notice of Proposed Rulemaking (âNPRâ) that will be joined by the Federal Deposit Insurance Corporation, National Credit Union Administration and the Office of the Comptroller of...more
3/28/2022
/ Administrative Proceedings ,
Comment Period ,
FDIC ,
Financial Institutions ,
FRB ,
Interagency Guidance ,
NCUA ,
NPRM ,
OCC ,
Rules of Practice ,
Uniform Standards