The Financial Stability Oversight Council’s (FSOC) recently revised guidelines (the 2019 Guidelines) on how it will identify and address financial stability risks are a major shift from the guidelines it issued in the immediate aftermath of the Financial Crisis.  The 2019 Guidelines draw upon lessons learned from FSOC’s ultimately fruitless attempts to designate nonbank financial companies as systematically important.  Instead, the 2019 Guidelines focus on identifying and regulating systemically important activities rather than entities, conducting…

On December 10, 2019, the CFTC reopened the comment period for the proposed capital requirements for swap dealers (SDs) and major swap participants (MSPs) that are not subject to the capital rules of a prudential regulator (together, Covered Swap Entities).  These rules are the last set of core requirements yet to be finalized for the CFTC’s SD regime.  At the same time, the CFTC separately proposed amendments to the exemption from the CFTC’s swap clearing…

As we enter the new year, we have updated our roster of federal financial regulatory leadership, including announced nominations, confirmations, resignations and expiring terms.  The first slide summarizes the state of play for the agencies’ principals; the later slides provide a deeper look on an agency-by-agency basis, including select senior staff.  We intend to continue to update this resource from time to time. View as a PDF …

Financial services regulatory reform will continue to be active in 2020, with developments percolating in all three branches of government.  As we observe the changing landscape, here is the 2020 Vision Edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and will provide another update in the next quarter. The Davis Polk Financial Services Regulatory…