Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
The Financial Stability Oversight Council unanimously approved an analytic framework for financial stability risk identification, assessment and response and interpretive guidance on nonbank financial company determinations...more
In Short - The Situation: Over the course of 2023, the Financial Stability Oversight Council ("FSOC") took steps that increase the risk of nonbank financial companies and financial activities being designated as...more
December 14, 2023 - FSOC Issues Annual Report- The Financial Stability Oversight Council released its 2023 annual report reviewing financial market developments, describing potential emerging threats to U.S. financial...more
Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more
On October 24, US banking regulators, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (the “agencies”), issued long-awaited guidance...more
Since the 2023 spring bank failures, the federal banking agencies have tinkered with significant bank regulations and guidance—ranging from capital, bail-in measures, and resolution planning to climate-risk stress testing,...more
On November 3, the Financial Stability Oversight Council (FSOC) voted unanimously to finalize the procedures for designating a nonbank financial company for Federal Reserve supervision. FSOC’s Interpretive Guidance aims to...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
On June 15, House Financial Services Committee Chairman Patrick McHenry sent a letter to Treasury Secretary Janet Yellen urging the Financial Stability Oversight Council (FSOC), which Yellen chairs, to “revisit” its proposals...more
June 17, 2023- Federal Reserve Bank of New York General Counsel Rachel Ostrander gave remarks on the panel "Bank Crisis Framework: Learning from Experience" at the Paris Meeting of the Committee on International Monetary Law...more
The Financial Stability Oversight Council on April 21, 2023, released for public comment a proposed analytic framework for financial stability risk identification, assessment and response (Proposed Framework) and proposed...more
April 21, 2023- The Financial Stability Oversight Council (Council) voted unanimously to issue for public comment a proposed analytic framework for financial stability risks. The Council also voted unanimously to issue for...more
February 10, 2023- The Department of the Treasury announced actions taken by the Committee on Foreign Investment in the United States (CFIUS) related to excepted foreign states (EFS). Specifically, CFIUS has determined that...more
Hearing: Oversight of the U.S. Securities and Exchange Commission- September 15, 2022- The U.S. Senate Committee on Banking, Housing, and Urban Affairs held a hearing entitled, "Oversight of the U.S. Securities and...more
In This Issue. The Treasury Department’s Financial Stability Oversight Council (FSOC) issued a report acknowledging climate change as threat to financial stability; Federal Reserve Governor Michelle Bowman advocates for...more
In a recent notice to the industry the Federal Insurance Office (“FIO”) set forth a series of requests to both life and property/casualty insurers for information as to the impact of climate change on both their insurance...more
On July 26, 2021, Neal R. Pandozzi participated as a presenter in the Strafford CLE webinar "The Phase-out of LIBOR: Navigating the Final Stages, Implementing Alternative Reference Rates and Fallback Language." The webinar...more
As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more
In This Issue. President Biden signed an executive order addressing climate-related financial risks; the Office of the Comptroller of the Currency (OCC) finalized a rule applicable to national banks and federal savings...more
In the News. The Consumer Financial Protection Bureau (CFPB), along with the Federal Trade Commission (FTC) and more than 50 federal and state law enforcement partners, announced Operation Corrupt Collector, a nationwide law...more
Insurance and Investment Firms Breathe Easier - On December 4, 2019, the Financial Stability Oversight Council adopted final interpretive guidance on addressing systemic threats to the financial system that prioritizes the...more
US lawmakers urge FSOC to designate cloud-based storage systems used by major banks as systemically important financial market utilities. In an August 22, 2019, letter addressed to Treasury Secretary Steven Mnuchin, in his...more
On May 6, 2019, the Board of Governors of the Federal Reserve System (the Board) published its annual Financial Stability Report....more
The Financial Stability Oversight Council Improvement Act of 2019 (the “Act”) was recently introduced in the United States Senate. Under existing law, the Financial Stability Oversight Council (“FSOC”) can subject certain...more