On January 29, 2024, the OCC issued a proposed policy statement[1] describing the general principles it uses to evaluate applications for approval of transactions under the Bank Merger Act (“BMA”), principally bank mergers,...more
Background. As part of an international effort to recalibrate how banks calculate their risk‑based capital, U.S. bank regulatory agencies (the “Agencies”) recently proposed major changes to how banks would be required to...more
On April 28, 2023, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the United States Government Accountability Office (GAO), and the New York Department of...more
On March 17, 2020, the Federal Deposit Insurance Corporation (FDIC) announced two significant developments relating to industrial banks (also sometimes called industrial loan companies). First, in a notice of proposed...more
On March 4, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) approved a final rule amending several of the Federal Reserve’s regulations and policies (and making associated changes to...more
On November 19, 2019, the federal banking agencies issued a final rule (the “Final Rule”) that incorporates a new definition of an “HVCRE exposure” into the U.S. regulatory capital rules. The new definition is substantially...more
On August 20, 2019, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) approved a final rule (the “2019 Final Rule”) to amend the rules implementing Section 13 of the Bank...more
On August 20, 2019, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) approved a final rule (the “2019 Final Rule”) to amend the rules implementing Section 13 of the...more
On July 12, 2019, the federal banking agencies released a notice of proposed rulemaking (July NPR) regarding the capital treatment of certain loans that finance land improvements but do not finance the construction of...more
On April 23, 2019, the Board of Governors of the Federal Reserve System (“Federal Reserve”) released a proposed rule (“Proposed Rule”) to revise regulations related to the determination of “control” under the Bank Holding...more
On April 8, 2019, the federal banking agencies (the “Agencies”) released two proposals (the “Tailoring Proposals”) which, if adopted, would further tailor the approach to supervision of large foreign banking organizations...more
The Federal Reserve and the FDIC published proposed changes to resolution plan (or “living will”) requirements applicable to U.S. and foreign banking organizations. The regulatory changes are necessary because the 2018...more
On November 21, 2018, the federal banking agencies (the “Agencies”) released a proposal (the “Proposed Rule”) to simplify the regulatory capital requirements for qualifying community banking organizations (QCBOs) (i.e.,...more
On October 31, 2018, the federal banking agencies released two separate proposals that, if adopted, would create a more consistent tiered approach to large bank supervision – in other words, supervision of banking...more
As reported in a prior Client Alert, new federal legislation enacted into law on May 24, 2018 narrows the types of acquisition, development, and construction (ADC) loans that may be subject to a heightened risk weight under...more
On May 30, 2018, the Board of Governors of the Federal Reserve System (“Federal Reserve”) issued a proposal (the “Proposed Rule”) to amend the rules implementing Section 13 of the Bank Holding Company Act of 1956 (the...more
May 11, 2018 was the applicability date for FinCEN’s new “Customer Due Diligence Requirements for Financial Institutions” (the “CDD Rule”). FinCEN noted the occasion by issuing a press release to remind covered financial...more
On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more