On November 1, 2021, the President’s Working Group on Financial Markets (“PWG”), joined by the Federal Deposit Insurance Corporation (“FDIC”) and the Office of the Comptroller of the Currency (“OCC”), released a report on...more
The release of the Pandora Papers, a leak of approximately 12 million documents, exposed how foreign leaders and private actors use tax havens to conceal their wealth, with the United States a destination of choice. For...more
10/18/2021
/ Anti-Money Laundering ,
Beneficial Owner ,
Due Diligence ,
Financial Fraud ,
Money Laundering ,
Offshore Funds ,
Pandora Papers ,
Proposed Legislation ,
Regulatory Agenda ,
Regulatory Reform ,
Regulatory Standards ,
Shell Corporations ,
Tax Evasion ,
Tax Haven ,
Trusts ,
White Collar Crimes
The 2020 Election Results and Implications for the Financial Services Industry -
Former Vice President Joseph R. Biden Jr. has won the 2020 presidential election and the Democratic Party will remain in control of the House...more
The Federal Reserve has released FAQs covering its recently revised control regulation, which became effective on September 30, 2020 (the “Control Rule”). For more on the specifics of the Control Rule, please refer to our...more
On June 25, 2020, the Federal Reserve, Farm Credit Administration, Federal Deposit Insurance Corporation, Federal Housing Finance Agency and Office of the Comptroller of the Currency (the “Agencies”) finalized amendments to...more
The Federal Reserve Board (the Federal Reserve), the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission (SEC) and the Commodity Futures...more
COVID-19 has acted as an accelerator, bringing into play scenarios which were previously only contingencies and making contingencies of (and requiring planning for) situations which were previously barely imaginable. The debt...more
On June 25, 2020, the Federal Reserve Board (the “Fed”) released (i) the results of its supervisory stress tests for 2020; and (ii) aggregate, not bank-specific, results of a special “sensitivity analysis” conducted under a...more
In the face of the coronavirus (COVID-19) pandemic, the U.S. Federal Reserve Board (the Fed) and the U.S. federal banking agencies have announced several market and supervisory actions to address the sudden market stress and...more
On March 31, 2020, the Board of Governors of the Federal Reserve System (the “Board”) announced that it has decided to delay the effective date of its final rules revising the Board’s framework for determining whether a...more
The New York Department of Financial Services (“NYDFS”) promulgated regulations (“Part 119”) on March 24, 2020, to provide financial relief to individuals who can demonstrate a financial hardship as a result of the COVID-19...more
In the face of the coronavirus (COVID-19) pandemic, the U.S. Federal Reserve Board (the Fed) and the U.S. federal banking agencies have announced several market and supervisory actions to address the sudden market stress and...more
In the face of the coronavirus (“COVID-19”) pandemic, the U.S. Federal Reserve Board (the “Fed”) and the U.S. federal banking agencies have announced several market and supervisory actions to address the sudden market stress...more
3/21/2020
/ Banking Sector ,
Banks ,
Capital Requirements ,
Commercial Paper ,
Coronavirus/COVID-19 ,
Emergency Response ,
FDIC ,
Federal Register ,
Federal Reserve ,
Financial Crisis ,
Financial Institutions ,
Financial Markets ,
FRBNY ,
Liquidity ,
OCC
The economic and operational stresses caused by the Novel Coronavirus (COVID-19) are highlighting the need for regulated financial institutions to formulate responses to address significant business disruptions (SBDs) and to...more
The arrival of Novel Coronavirus (“COVID-19”) in New York, and the United States more generally, has roiled the U.S. and global economy and significantly affected numerous businesses. In light of these circumstances, the New...more
The arrival of Novel Coronavirus (COVID-19) in New York, and the United States more generally, has roiled the U.S. and global economy and significantly affected numerous businesses. In light of these circumstances, the New...more
On January 30, 2020, the Federal Reserve Board (the “Board”) adopted final rules (the “Final Control Regulation”) to provide increased transparency and consistency around determining when an investor company has “control”...more
2/20/2020
/ Bank Holding Company Act ,
Board of Directors ,
Controlling Influence Test ,
Federal Reserve ,
Fiduciary Duty ,
Final Rules ,
HOLA ,
Interlocking Directorate ,
Investment Funds ,
Investors ,
Proxy Contests ,
Rebuttable Presumptions ,
Senior Managers ,
Voting Securities
At the end of December, the New York Department of Financial Services (the NYDFS) published an industry letter to regulated institutions regarding LIBOR cessation. The NYDFS is requiring that each “regulated institution”...more