On April 8, 2019, the federal banking agencies released two proposals which, if adopted, would further tailor the approach to supervision of large foreign banking organizations (FBOs). For FBOs with a more significant U.S. presence, the proposals would establish categories for the application of requirements based on size and certain other risk-based indicators. These categories would parallel the tailored framework proposed for the supervision of large domestic banking organizations released in November 2018. Read our client …

On April 8 and 16, 2019, the Federal Reserve and the FDIC published proposed changes to resolution plan (or “living will”) requirements applicable to U.S. and foreign banking organizations. The regulatory changes are necessary because the 2018 Regulatory Relief Act raised the asset thresholds for applicability of the living will requirements. The proposal would apply different filing frequency and informational content requirements based on the risk a firm poses to the U.S. financial system. Read our…

Yesterday, five federal agencies – the Federal Reserve Board, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the Bureau of Consumer Financial Protection – issued a two-page, joint statement on the role of supervisory guidance for regulated institutions. Although brief, the joint statement is significant. Read our client alert.…

Two key federal government announcements were made on July 31, 2018 related to fintech issues. First, the U.S. Department of the Treasury issued a press release announcing a report entitled “Nonbank Financials, Fintech, and Innovation.” The Report is the fourth and final in a series of reports prepared by Treasury in response to President Trump’s February 2017 Executive Order 13772. In addition, the Office of the Comptroller of the Currency announced that it would begin…

The CFPB issued its second in a series of Requests for Information on January 31, 2018; this one dealing with administrative adjudications. In the associated press release, the Bureau explained that it “is seeking to better understand the benefits and impacts of its use of administrative adjudications, and how its existing process may be improved.” The CFPB is currently issuing a series of RFIs to “ensure the Bureau is fulfilling its proper and appropriate functions…