Tag Archives: Federal Reserve Board

Federal Reserve Board Announces Six-Month Delay of Effective Date of Control Framework

Yesterday, March 31, 2020, the Board of Governors of the Federal Reserve System (the “Board”) announced a six-month delay in the effective date of its final rule implementing a revised control framework.  Previously, in January, the Board unanimously approved a final rule establishing a comprehensive, simplified framework for determining when an investor company exhibits control … Continue Reading

Federal Reserve Establishes Temporary FIMA Repo Facility

Yesterday, March 31, 2020, the Board of Governors of the Federal Reserve System (the “Board”) announced the creation of a temporary repurchase agreement facility for foreign and international monetary authorities (the “FIMA Repo Facility” or the “Facility”) to facilitate liquidity for central banks and other international monetary authorities.  The FIMA Repo Facility is the latest … Continue Reading

Agencies Encourage Banks to Make Small-Dollar Loans to Customers Affected by Coronavirus

Today, March 26, the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency released an interagency statement encouraging financial institutions to offer responsible small-dollar loans to both consumers and small businesses facing … Continue Reading

Federal Reserve Takes Unprecedented Action to Provide Financial Assistance to U.S. Companies

Yesterday, March 23, the Board of Governors of the Federal Reserve System (the “FRB”) announced the latest in a series of extraordinary actions intended to help mitigate the impacts of the COVID-19 pandemic on the U.S. economy.  Unlike the measures announced last week – which mostly involved re-establishing emergency programs that were used during the … Continue Reading

Banking Regulators Release Interagency Statement on COVID-19 Related Loan Modifications

On Sunday, March 22, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Consumer Financial Protection Bureau, and the Conference of State Bank Supervisors released an Interagency Statement encouraging financial institutions to work with borrowers affected … Continue Reading

GOP Stimulus Bill Includes Banking and Financial Markets Relief

Yesterday, on Sunday, March 22, 2020, U.S. Senate Republicans released the latest version of their COVID-19-related stimulus bill, the Coronavirus Aid, Relief, and Economic Security Act or CARES Act.  The bill contains several measures intended to provide relief to banks, their customers, and broader financial markets. The latest version of the CARES Act includes the … Continue Reading

Federal Reserve Eases Application of TLAC Buffer

Today, March 23, 2020, the Federal Reserve issued an interim final rule that revises the definition of “eligible retained income” for purposes of the total loss-absorbing capacity (“TLAC”) buffer requirements that apply to global systemically important banking organizations (“G-SIBs”).  The rule amends the “eligible retained income” definition in the same manner as the federal banking … Continue Reading

Federal Reserve to Accept U.S. Municipal Short-Term Debt as Eligible Collateral Under Expanded MMLF Program

Today, March 20, 2020, the Federal Reserve announced that it has amended the terms of its recently announced Money Market Mutual Fund Liquidity Facility (“MMLF”) so as to accept certain U.S. municipal short-term debt as eligible collateral and allow additional types of funds to sell eligible collateral to participating borrowers.  The expansion is intended to … Continue Reading

Federal Reserve Establishes Money Market Mutual Fund Facility to Support Liquidity of Key Financial Assets

Yesterday, on March 18, 2020, the Board of Governors of the Federal Reserve System (“Board”) announced the creation of a Money Market Mutual Fund Liquidity Facility (“MMLF”) to provide liquidity support to money market mutual funds (“MMMFs”) by facilitating their sale of certain assets in order to meet redemption requests.  Under the MMLF, the Federal … Continue Reading

In Response to COVID-19, Banking Agencies Issue Interim Final Rule Revising Capital Buffer Requirements to Promote Lending

Today, March 17, 2020, the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “FRB”), and the Federal Deposit Insurance Corporation (the “FDIC”) released an interim final rule that revises the definition of “eligible retained income” in the regulatory capital rules that apply to U.S. … Continue Reading

Federal Reserve Takes Extraordinary Actions Supporting Financial Markets to Mitigate COVID-19 Impact

Yesterday, on Sunday, March 15, 2020, in response to the COVID-19 pandemic’s impact on U.S. and global economic activity, the Federal Reserve’s Federal Open Market Committee (“FOMC”) cut the target range of the federal funds rate to 0 to 1/4 percent until such time as the FOMC is “confident that the economy has weathered recent … Continue Reading

Proposal Would Simplify Volcker Rule’s “Covered Funds” Provisions

On January 30, 2020, five federal financial regulators jointly issued a proposed rule that would modify existing regulations implementing the Volcker Rule’s general prohibition on banking entities investing in, sponsoring, or having certain relationships with hedge funds or private equity funds (collectively, “covered funds”).  The proposal, which follows a 2019 final rule revising the Volcker … Continue Reading

Federal Reserve Finalizes Comprehensive Framework for Determining “Control”

On January 30, 2020, the Board of Governors of the Federal Reserve System unanimously approved a final rule that establishes a comprehensive framework for determining whether a company controls another company for purposes of the Bank Holding Company Act and Home Owners’ Loan Act, and clarifies certain control-related concepts. After decades in which questions of … Continue Reading

FRB Governor Brainard Discusses Path Forward on Community Reinvestment Act Reform

On January 8, 2020, Federal Reserve Board (“FRB”) Governor Lael Brainard delivered remarks on the state of Community Reinvestment Act (“CRA”) reform before an audience at the Urban Institute.  As we summarized in a client alert, last month, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) released … Continue Reading

GAO Concludes Three SR Letters Are Rules Under Congressional Review Act

On October 22, 2019, the U.S. Government Accountability Office (“GAO”) issued two letters concluding that three Federal Reserve Supervision and Regulation letters, SR 12-17: Consolidated Supervision Framework for Large Financial Institutions, SR 14-8: Consolidated Recovery Planning for Certain Large Domestic Bank Holding Companies, and SR 11-7: Guidance on Model Risk Management, are “rules” under the … Continue Reading

Agencies Propose CECL Policy Statement

On October 17, 2019, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, and National Credit Union Administration released for public comment a proposed interagency policy statement on allowances for credit losses (“ACLs”).  The proposed policy statement reflects the Financial Accounting Standards Board’s adoption … Continue Reading

CFTC Becomes Third Federal Financial Regulator to Approve Volcker Rule Reforms

On Monday, September 16, the Commodity Futures Trading Commission (the “CFTC” or the “Commission”) announced that it has approved final regulations (the “final rule”) that will streamline and clarify the Volcker Rule – a statutory provision that generally prohibits banking entities from engaging in proprietary trading, or from taking an ownership interest in, sponsoring, or … Continue Reading

Federal Reserve Rationalizes Stock Buyback Rules

On July 9, 2019, the federal banking agencies released a final rule to simplify aspects of the regulatory capital rules for banking organizations that are not “advanced approaches” banking organizations, i.e., those with less than $250 billion in total consolidated assets and less than $10 billion in total foreign exposure.  Initially proposed in September 2017 … Continue Reading

Federal Banking Agencies Propose TLAC Deduction Standard

On April 2, 2019, the federal banking agencies proposed a rule that would require large banking organizations to deduct from their regulatory capital certain investments in total loss-absorbing capacity (“TLAC”) debt issued by global systemically important banking organizations (“G-SIBs”) rather than to risk-weight such investments as is currently done.  The rule is intended to reduce … Continue Reading

Agencies to Revise SLR to Exclude Custodial Deposits at Central Banks

On March 29, 2019, the board of the FDIC approved a notice of proposed rulemaking that would revise the supplementary leverage ratio (“SLR”) to exclude certain deposits placed at central banks from custodial banks’ SLR denominators, implementing section 402 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (“EGRRCPA”).  The OCC and Federal Reserve … Continue Reading

Federal Reserve Eliminates CCAR’s Qualitative Objection for Most Firms

On March 6, 2019, the Federal Reserve issued a final rule to exempt from the qualitative component of the Comprehensive Capital Analysis and Review (“CCAR”) exercise large firms that have participated in CCAR for four consecutive years and have passed the final year’s qualitative component without objection.  The final rule serves to provide an immediate … Continue Reading

Government Shutdown Could Affect Federal Reserve Processing of M&A Applications

The partial federal government shutdown could affect the timing of processing of certain new merger and acquisition applications by the Board of Governors of the Federal Reserve System (the “Board”). Pursuant to special procedures outlined in a December 2018 notice, the Office of the Federal Register is not publishing documents during the partial government shutdown … Continue Reading
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