Michael E. Bleier

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This post was also written by James C. Martin. In SEC v. Citigroup Global Markets, Inc., 2014 WL 2486793 (2d Cir. June 4, 2014), the U.S. Court of Appeals for the Second Circuit has reversed and vacated U.S. District Court Judge Jed Rakoff’s controversial 2011 decision refusing to approve a consensual settlement agreement between the SEC and Citigroup Global Markets, Inc. While Judge Rakoff did not require an admission of wrongdoing as a condition of…
This post was also written by Timothy Nagle and Christopher Fatherley. The New York Department of Financial Services (“DFS”) has joined the growing chorus of financial regulators expressing heightened concern for bank cybersecurity preparedness. On May 6, 2014 New York’s Governor Andrew M. Cuomo released a 13 page “horizontal perspective” entitled Report on Cyber Security in the Banking Sector. The document is co-endorsed by Benjamin M. Lawsky, New York State’s Superintendent of Financial Services. The report…
Friday afternoon, the Federal Reserve Board (“Board”) considered and approved in an open board meeting, proposed rules to implement the enhanced prudential standards and early remediation requirements of sections 165 and 166 of the Dodd-Frank Act for foreign banking organizations (“FBOs”), and those foreign nonbank financial companies designated by the Financial Stability Oversight Council for Board supervision. The proposed rules will be out for public comment for 90 days following publication in the Federal Register.…
The impact of a breakup of the euro, whether by a large or small Eurozone member, will have significant consequences for US-headquartered financial services providers. Not only are those US companies among the key players with operations in the Eurozone, but many of them are among the largest foreign exchange traders in the world. An immediate consequence will be felt in their critical relationships with their US regulators, at the same time there will be…
On May 9, 2012, the Federal Reserve Board (“FRB”) released three orders approving investments in the U.S. banking market by entities based in China. The investments, which consist of the acquisition of 80 percent of a national banking association and the establishment of two foreign branch offices, are particularly notable because the investments are coming from China. The Chinese Government will be an indirect owner of a national bank, and the conclusions that the FRB…
On Friday, May 4, Michael Bleier will be making a presentation at the Annual Meeting in Washington, DC of the Lawyers Council for the Financial Services Roundtable. He will be talking about his observations regarding the role of General Counsel for a major financial services provider, in his case over the 14 years he was General Counsel for Pittsburgh’s Mellon Financial Corporation.  …
On February 14, 2012, the Federal Reserve Board (“Board”) announced its approval of Capital One Financial Corporation (“Capital One”) to acquire the shares of ING Bank, fsb (“ING”). In its order approving the acquisition, the Board reaffirmed its test for determining financial stability in light of the new criteria required by Dodd-Frank to the analysis of expansion applications pursuant to the Bank Holding Company Act (12 U.S.C. §§ 1842 and 1843) (“BHC Act”), which was…
On January 5, 2012, the Federal Reserve Board (“FRB”) published in the Federal Register a notice of proposed rulemaking (77 Fed. Reg. 594 (Jan. 5, 2012)) that would implement the enhanced prudential standards required to be established under Section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”), and the early remediation requirements established under Section 166 of the Dodd-Frank Act. To read the entire alert, please visit reedsmith.com.…
While the focus of in-house counsel has appropriately been on the Dodd Frank Act and its avalanche of required rulemakings, a probably more impactful set of requirements are going to come from the Basel III capital and liquidity rules.  As a result of the financial crisis of the past few years, the Basel Committee on Banking Supervision (“Basel Committee”), with the support of, and at the direction of the G-20 Government Heads, has significantly modified…