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Federal Reserve Releases FAQs on Select “Control” Issues

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

LIBOR Summer Update: Regulatory Scrutiny Heats Up on Transition Preparedness

With fewer than 18 months until the expected cessation of the London Interbank Offered Rate (LIBOR), regulators have developed a keen interest on how financial institutions are preparing to transition from what has been...more

Federal Reserve Releases Stress Test Results: Restrictions on Share Repurchases and Dividends in Response to COVID-19

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

The Fed Moves Beyond the Financial Crisis Playbook for Pandemic Response

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

Federal Reserve Board to Extend Effective Date for the Final Control Regulation

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

NYDFS Adopts Forbearance Regulations for Regulated Institutions

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

UPDATED - The Fed Repurposes the Financial Crisis Playbook for Pandemic Response

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

The Fed Repurposes the Financial Crisis Playbook for Pandemic Response

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

Planning in a Time of Pandemic: Considerations for Regulated Financial Institutions in the US, EU and UK

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

New York Department of Financial Services Publishes Letter On LIBOR Cessation Readiness

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

SEC Chairman Announces Significant Changes to Commission Procedures for Considering Disqualification Waivers

On July 3, 2019, Chairman Jay Clayton of the Securities and Exchange Commission (SEC) issued a Statement Regarding Offers of Settlement (the “Public Statement”) to announce a significant shift in the SEC’s process of...more

Financial Regulatory Developments Focus - November 2018

In this week's newsletter, we provide a snapshot of the principal U.S., European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - October 2018 #2

In this week's newsletter, we provide a snapshot of the principal U.S., European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - September 2018 #3

In this week's newsletter, we provide a snapshot of the principal U.S., European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - November 2017 #3

In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more

Rethinking US Financial Regulation in Light of the 2016 Election

Throughout his campaign, Donald Trump wavered between populist and business-friendly policies and expressed seemingly conflicting plans for Wall Street—on the one hand advocating for less regulation with a repeal of the...more

Financial Regulatory Developments Focus - September 2016

In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more

Brexit and Equivalence: Review of the Financial Services Framework Across All Sectors

Since the UK voted to leave the EU on 23 June 2016, there has been much speculation about the form of the future access arrangements between the UK and the EU for financial institutions. In a scenario where no new deal is...more

NYS Department of Financial Services Outlines Requirements for Transaction Monitoring and Filtering Programs of NY State-Licensed...

On June 30, 2016, the New York State Department of Financial Services (“NYSDFS”) adopted a final regulation outlining the attributes of a risk-based transaction monitoring and filtering program that certain New York...more

The Re-Proposed Rule on Incentive-Based Compensation at Financial Institutions: Overview and Observations

To date, five of the six federal regulators (the “Agencies”) charged with promulgating rules under Section 956 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) have approved a joint proposed...more

Financial Regulatory Developments Focus - November 2015 #4

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - November 2015

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Implementation Issues Arising from the Revised UK Senior Manager and Certification Regime

The UK Government recently announced that it would introduce a new statutory duty of responsibility on senior managers in all financial institutions and repeal the presumption of responsibility that would have applied to...more

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