First Republic Executives Fail in Attempt to Recover Nonqualified Deferred Compensation Plan Assets
Consumer Finance Monitor Podcast Episode: Interest Rate Exportation Under Attack Part II
Consumer Finance Monitor Podcast Episode: Interest Rate Exportation Under Attack Part I
Consumer Finance Monitor Podcast Episode: Banks and Their Customer Relationships: What is the Appropriate Role of Bank Regulators?
Compliance into the Weeds: Scathing Report on Culture at The FDIC
2024 Regulatory Hot Topics
Consumer Finance Monitor Podcast Episode: Community Reinvestment Act Reform: A Close Look at the Final Rule
Consumer Finance Monitor Podcast Episode: What the Recent Developments in Federal Preemption for National and State Banks Mean for Bank and Nonbank Consumer Financial Services Providers
Federal Banking Interagency Final Guidance on Third-Party Relationships - The Consumer Finance Podcast
Evaluating Government Sanctions in the Payments Industry - Payments Pros: The Payments Law Podcast
Consumer Finance Monitor Podcast Episode: A Deep Dive Into Cryptocurrency and its Risks to Investors and the Banking System, with Arthur E. Wilmarth, George Washington University Law School
CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast
CFPB's Policy Statement on Abusiveness (Part 1) - The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: How a Former FDIC Chairman is Reacting to the Silicon Bank Valley Failure, A Discussion with Special Guest Bill Isaac, Chairman, Secura/Isaac Group, and FDIC
Crypto Year in Review 2022: Federal Reserve and Central Bank Digital Currencies and FDIC/OCC Regulatory Developments - The Crypto Exchange Podcast
Use of the FDIC Name and Logo: Proceed With Caution
All Talk, No Action? The Fintech Regulatory Plot Thickens
Congressional and Federal Agency Action Following Executive Order on Digital Assets Policy
The Sanity of Bank Directors
Regulators Tackle Board Effectiveness and Overdrafts
On June 6, 2024 federal regulators published a final rule addressing Quality Control Standards for Automated Valuation Models. This was a collaborative rulemaking effort that included regulators from the Office of the...more
On September 18, 2023, the U.S. Basel III Endgame proposal was published in the Federal Register. The comment period ended on January 16, 2024, with the banking regulators (the Federal Reserve, the OCC, and the FDIC) having...more
As we prepare to put 2020 in the rearview mirror, many of us will not have fond memories of the year. Quarantines, masks, social distancing, unspeakable tragedy, economic ruin for some industries. But the fintech world proved...more
In 2015, the Second Circuit’s decision in Madden v. Midland Funding, LLC, raised doubts about whether banks could transfer, sell, or assign their interests in consumer debt without triggering the enforcement of state usury...more
The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity Futures Trading...more
The Situation: The Federal Reserve, Office of the Comptroller of the Currency ("OCC"), Federal Deposit Insurance Corporation ("FDIC"), Securities and Exchange Commission ("SEC"), and Commodity Futures Trading Commission...more
The Second Circuit’s decision in Madden v. Midland Funding, LLC was announced in 2015. Since that time, there have been a number of cases brought based on the Second Circuit opinion, as well as recent regulatory proposals...more
On January 30, 2020, the Board of Governors of the Federal Reserve System (“FRB”), the Federal Deposit Insurance Corporation (“FDIC”), the Office of the Comptroller of the Currency (“OCC”), the Securities and Exchange...more
The federal agencies responsible for the Volcker Rule have proposed to clarify some requirements for exclusion from the definition of “covered fund” and to increase the types of funds excluded from that definition. The...more
Last week the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission and the Commodity Futures...more
On January 30, 2020, the U.S. Securities and Exchange Commission (SEC), the Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (“Fed”), the Federal Deposit...more
Since its adoption in 2010, the Federal Deposit Insurance Corporation’s (the “FDIC”) securitization safe harbor rule, 12 C.F.R. § 360.6 (the “Rule”), which relates to the treatment of financial assets transferred in...more
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 Industry Developments - Prohibition on Dealing or Investing in Industrial or Commercial Metals - On January 3, 2017, the Office of the Comptroller of the Currency (the "OCC") finalized a rule that...more
On October 22, 2014, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, the Federal Housing...more
Federal Reserve, OCC, FCA, FHFA and FDIC Adopt Joint Final Rule on Swap Margin Requirements - On October 22, the Office of the Comptroller of the Currency (the "OCC"), the Federal Reserve Board (the "Board"), the Farm...more
On October 22, 2015, the Federal Deposit Insurance Corporation held an open meeting at which it voted to adopt: (i) final rules governing margin and capital requirements for uncleared swaps and (ii) an interim final rule to...more
Effective December 24, 2015, all securitizations of residential mortgage loans (RMBS), both public and private, will be subject to the Credit Risk Retention Rule (the “Rule”).[1] The Rule was promulgated on December 24, 2014,...more
On Monday, August 24, 2015, the Federal Deposit Insurance Corporation (FDIC) released the Summer 2015 issue of its Supervisory Insights publication. In addition to providing a brief review of recently released regulations and...more
After three years of waiting, we now have our Risk Retention Rule. All six of the Agencies responsible for the Rule – the FDIC, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the...more
On October 22, 2014, six federal agencies adopted the final Credit Risk Retention Rule under Section 941 of the Dodd-Frank Act. The final rule will require sponsors of securitizations to retain an economic interest in the...more
CLO managers and lead arrangers of syndicated loans received special attention in a proposal jointly released by six federal agencies to implement the credit risk retention requirements of Section 941 of the Dodd-Frank Act....more