There are distinct, but subtle, shifts in tone in the FSOC’s 2017 Annual Report, especially when compared to previous annual reports and read together with three recent Treasury reports...
The Senate’s bipartisan regulatory relief bill advanced out of the Senate Banking Committee this week with only minor changes and remains on a path to a filibuster-proof majority. The ...
Does the bipartisan Senate bill described in our earlier post leave large banks, i.e., banking organizations with $250 billion or more in total consolidated assets, and foreign banking or...
The bipartisan Senate bill would open the door to welcome relief for regional and community bank holding companies (BHCs) by raising the statutory threshold for enhanced prudential standa...
The Trump Treasury Department’s vision for how the FSOC should fulfill its mission is emerging.[1] Ironically, this new, and we think better vision, may be closer to how the Obama Trea...
The Leveraged Lending Guidelines are in an uncomfortable state of limbo. After the GAO ruling that the Guidelines are a “rule” under the Congressional Review Act, they are no longer ...
Buried in the latest Treasury Report, the third in a series, are important gems on the Volcker Rule and on the concept of controlling influence.[1] Of the three interesting new recommend...
The OCC’s recent revision to its Community Reinvestment Act examination and ratings policies is a welcome first step in a long overdue and much needed rethink of how supervisors might m...
Many have commented on the suit filed last week challenging the CFPB’s arbitration rule, but few have considered what impact, if any, the suit could have on the fast-approaching complia...
Recently, certain derivatives clearinghouses have changed their rulebooks to treat daily payments of mark-to-market variation margin as settlement payments of the derivatives transactions...
