Too Big To Fail in the Dodd-Frank Era
Rodge Cohen: Dodd-Frank Fixes "Too Big To Fail"
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: The Financial Stability Oversight Council ("FSOC") recently issued a "notification of proposed interpretive guidance" on updated procedures for designating nonbank financial companies as...more
On April 21, 2023, the Financial Stability Oversight Council ("FSOC") issued two important proposals regarding the designation of a nonbank financial firm as a systemically important financial institution ("nonbank SIFI")...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
In prepared remarks before the American Council of Life Insurer's Executive Roundtable (Naples, Florida, 9 January 2019), Federal Reserve Board (FRB) Vice Chairman for Supervision Randal Quarles provided the insurance...more
Marketing Private Life Insurance Separate Accounts to Smaller Banks - Subject to certain exceptions, the so-called “Volcker rule” provisions of the Dodd-Frank Act and regulations thereunder (collectively, the Volcker Rule)...more
On May 24, 2018, President Trump signed the Economic Growth, Regulatory Relief and Consumer Protection Act (the “Reform Act”). The bulk of reform in the Reform Act consists of the elimination of many technical and...more
On May 24, President Trump signed into law the most significant banking legislation since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank”) in 2010. The bill – named the Economic...more
The US House included the revised Volcker Rule that we’ve discussed in a broader package of Dodd-Frank reforms that it passed with bipartisan support last night. The bill—ostensibly aimed at easing restrictions on small to...more
On March 14, 2018, the U.S. Senate approved the Economic Growth, Regulatory Relief and Consumer Protection Act, a bipartisan bill that would repeal or modify certain provisions of the Dodd-Frank Act and eliminate or ease a...more
On March 21, the House Financial Services Committee approved a proposal to loosen many of the rules implemented as part of the landmark 2010 Dodd-Frank legislation that overhauled the U.S. financial system in the wake of the...more
During the Trump Administration’s first year in office, it has implemented major new policy approaches and engaged in significant reversals of Obama Administration policies in many areas. In contrast, the Administration to...more
The U.S. Department of the Treasury (Treasury) recently released its long-awaited review of the determination and designation processes of the Financial Stability Oversight Council (FSOC), created under the Dodd-Frank Wall...more
The U.S. Department of the Treasury (Treasury) recently released a report examining the regulatory framework for the asset management and insurance industries (Report). The Report is the third in a series of four reports that...more
Mike Crapo, chairman of the US Senate Committee on Banking, Housing, and Urban Affairs, introduced the Economic Growth, Regulatory Relief and Consumer Protection Act which would introduce significant financial regulatory...more
On November 16, Senate Banking Committee (“SBC”) Chairman Mike Crapo (R-ID) introduced S. 2155, the “Economic Growth, Regulatory Relief and Consumer Protection Act,” long-awaited Senate legislation designed to foster economic...more
The Financial Stability Oversight Council (FSOC) on September 29, 2017 issued a determination rescinding its prior designation of American International Group, Inc. (AIG) as a systemically important financial institution...more
Editor's Note - State Regulators Sue OCC Over Federal FinTech Charter. On April 26, the Conference of State Bank Supervisors (CSBS) sued the Office of the Comptroller of the Currency (OCC) in the U.S. District Court for...more
Companies that the Financial Stability Oversight Council (FSOC) believes may be subject to FDIC receivership under the Orderly Liquidation Authority contained in Title II of the Dodd-Frank Act, and certain of their...more
During the recent campaign, President-elect Donald Trump pledged to repeal the Dodd-Frank Act (DFA) if elected, criticizing the regulatory burdens it imposed and contending that it discouraged lending by banks and impaired...more
The US House of Representatives passed a bill (H.R. 6392) that would replace the current supervisory framework under the Dodd-Frank Act that automatically subjects all bank holding companies with $50 billion or more in total...more
A bill in Congress would significantly amend the Dodd-Frank Wall Street Reform and Consumer Protection Act (Pub. L. 111–203) to change what institutions might be designated a systemically important risk requiring additional...more
While no one knows for sure what the future holds for investment management regulation, the tea leaves indicate that we may expect a slowdown on new regulations, some pullback on parts of the Dodd-Frank Wall Street Reform and...more
During the recent election campaign, President-elect Donald Trump pledged to repeal the Dodd-Frank Act if elected, criticizing the regulatory burdens it imposed on different portions of the financial services sector and...more