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High Quality Liquid Assets

This is not about top-shelf liquor, it is about today’s notice of proposed rulemaking…. At an open meeting today, the Federal Reserve Board (“FRB”) approved a proposed rule implementing a liquidity coverage ratio (“LCR”)...more

OFR Report: Asset Managers Potentially Threaten Financial Stability

Asset managers create vulnerabilities “that could pose, amplify, or transmit threats to financial stability,” according to the Treasury Department’s Office of Financial Research (OFR) in a September 2013 report....more

CFPB Signals Additional Concerns about Consumer Credit Card Market with Report on CARD Act

Yesterday, the Consumer Financial Protection Bureau (“CFPB”) released the “CARD Act Report,” a report summarizing the CFPB’s views on the impact of the Credit Card Accountability Responsibility and Disclosure Act of 2009...more

NY Fed to Establish an Overnight Fixed-Rate Reverse Repo Facility Available to Money Market Funds and Others

The New York Fed quietly announced it is testing a “new tool” that would provide a lifeline for yield-starved money market funds. In a speech today at Fordham University, William C. Dudley, president and chief...more

D.C. District Court Finds Fed Interchange Rules Are Invalid

On July 31, 2013, the U.S. District Court for the District of Columbia (“District Court”) issued a sharply worded Memorandum Opinion in the merchant litigation with the Federal Reserve Board (“Board”) regarding the Board’s...more

They’re Here: The Final Interagency Regulatory Capital Rules

The Federal Reserve Board today approved the publication of the long-awaited final regulatory capital rules (“Final Rules” ), which were proposed one year ago (the “Proposed Rules”). While today’s action was taken by the...more

SEC Proposes Floating NAV for Institutional Prime Money Market Funds; “Fees and Gates” for Non-Government Funds

The Securities and Exchange Commission today unanimously proposed two alternative requirements for money market funds. First, the SEC would require institutional prime money market funds to operate with a floating net asset...more

The Basel Committee Proposes to Double Down on Counterparty Exposure Limits

On March 26, the Basel Committee on Banking Supervision (“Basel Committee”) published a Consultative Document in which it proposes a revised supervisory framework for measuring and controlling large counterparty exposures...more

D.C. Circuit Hands the CFPB a Setback?

At the end of last week, the U.S. Court of Appeals for the District of Columbia Circuit issued its decision in Noel Canning v. National Labor Relations Board, holding that President Obama’s recess appointments to the National...more

MMF Independent Trustees in Crisis: MMF Executives Sue Independent Trustees for Fraud and Waste of Corporate Assets

In a bizarre twist to the case of the money market fund that broke the buck, the investment adviser to the Reserve Primary Fund (Reserve Fund) and its principals sued the fund’s independent trustees, laying the blame for the...more

Dodd-Frank Implementation: Navigating the Road Ahead

Table of Contents: Introduction; Financial Stability Reform; Resolution Planning; Agencies and Agency Oversight Reform; Securitization Reform; Derivatives Regulation; Investor Protection Reform; Credit Rating Agency...more

Financial Services Report -- Winter 2012

In This Issue: Bureau Report; Operations Report; Beltway Report; Arbitration Report; Mortgage Report; Privacy Report; Preemption Report; and Plastics Report. Excerpt from the Bureau Report: World’s Most...more

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