John C. Dugan

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CHOICE Act 2.0: House Financial Services Committee Revises Regulatory Reform Bill

On April 19, 2017, the House Financial Services Committee released a new discussion draft of the Financial CHOICE Act, its comprehensive regulatory reform bill.  The Committee released the first version of the CHOICE Act in June 2016.  Buoyed by the election of a Republican president, and following several months of public and industry outreach, Committee … Continue Reading

Getting Started Guide for Recovery Planning

On September 29, 2016, the Office of the Comptroller of the Currency issued final guidance for recovery planning.  The Guidance applies to insured national banks, federal savings associations and federal branches of foreign banks with average total consolidated assets of $50 billion or more. We partnered with Ernst & Young LLP to prepare a getting … Continue Reading

President Trump Begins Efforts to Roll Back Financial Regulations

Throughout his campaign, President Donald Trump promised to curtail financial regulations, particularly those promulgated under the Dodd-Frank Act.  President Trump argued frequently that the regulations issued under the act have proven overly burdensome and, among other things, limited job growth.  This afternoon, the President took his first formal step in implementing his deregulatory agenda.  He … Continue Reading

Federal Reserve Issues Final Standard for Long-Term Debt, Total Loss Absorbing Capacity, and Clean Holding Company Requirements for Largest Banking Organizations

On December 15, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued a final rule requiring global systemically important banking organizations (“G-SIBs”) to issue minimum amounts of “plain vanilla” unsecured long-term debt and total loss-absorbing capacity (“TLAC”) instruments, and to maintain so-called “clean” holding companies that have no “runnable” liabilities. … Continue Reading

OCC to Issue Special Purpose National Bank Charters to Fintech Companies

On December 2, 2016, Comptroller of the Currency Thomas J. Curry announced that the Office of the Comptroller of the Currency (“OCC”) would move forward with issuing special purpose national bank charters to financial technology (“fintech”) companies. The OCC released a whitepaper outlining its authority to issue charters to fintech companies, its approach to supervising … Continue Reading
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