Alba Baze

Davis Polk since 2017.

Latest Articles

The Federal Reserve, FDIC and OCC (the Banking Agencies) recently published a proposal to increase the thresholds associated with the “major assets” prohibition governing management official interlocks contained in the Depository Institutions Management Interlocks Act (DIMIA)[1] and implemented by Regulation L.  DIMIA permits the Banking Agencies to raise the statutory thresholds from time to time to take into account inflation or market changes.[2]  The thresholds have not been raised since 1996.[3] The…
Davis Polk has submitted a comment letter on the FDIC’s Request for Information on FDIC Communication and Transparency.   Our comment letter concentrates on ways in which we believe that the FDIC could improve its website, with a particular focus on how the FDIC’s efforts could educate users and ameliorate confusion by: Providing background materials regarding the legal framework of the regulatory state Reorganizing and clearly labeling its content consistent with the hierarchy of the…