Tag Archives: Federal Reserve

Federal Reserve Releases Capital Planning Proposal

On September 30, 2020, the Federal Reserve released a proposal to update its capital planning requirements in a number of respects, including to integrate the capital plan rule with the Federal Reserve’s October 2019 final rules tailoring its enhanced prudential standards.  The proposal would make the following notable changes: Replacement of Company-Run Stress Testing for … Continue Reading

Federal Reserve Bank of New York Releases Updated Documentation and Guidance on TALF

On June 8, 2020, the Federal Reserve Bank of New York (“FRBNY”) published revised FAQs and three updated transaction documents for the Term Asset-Backed Securities Loan Facility (“TALF”).  The three documents are the (i) Form of Issuer and Sponsor Certification as to TALF Eligibility for ABS, the Form of Indemnity Undertaking for ABS; (ii) the … Continue Reading

Federal Reserve Changes Terms of Main Street Lending Program to Expand Borrower Eligibility

On June 8, 2020, the Federal Reserve Board (“Board”) announced changes to its Main Street Lending Program (“MSLP”) intended to allow more small and medium-sized businesses to participate in the MSLP.  The Board also published updated term sheets for each of the MSLP facilities reflecting these changes; to illustrate how these changes affect the term … Continue Reading

Federal Agencies Share Principles for Offering Small-Dollar Loans

On May 20, 2020, the federal financial institution regulatory agencies—the Federal Reserve Board, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency—issued principles for responsibly offering small-dollar loans in order to meet consumers’ growing short-term credit needs.… Continue Reading

Federal Reserve Publishes Additional Detail on TALF

On Wednesday, May 20, 2020, the Board of Governors of the Federal Reserve System (the “Board”) announced further details on the Term Asset-Backed Securities Loan Facility (“TALF”).  The Board’s announcement contains key documents and forms, including the Master Loan and Security Agreement; updated FAQs and a blackline reflecting changes made against the version published on … Continue Reading

Temporary SLR Relief Extended to Banks, With Condition

On May 15, 2020, the federal banking agencies issued an interim final rule to permit depository institutions to exclude from their supplementary leverage ratio (“SLR”) denominators through March 31, 2021 the balance sheet value of U.S. Treasury securities and funds on deposit at a Federal Reserve Bank, subject to restrictions on capital distributions.  The interim … Continue Reading

Federal Reserve Announces Further Details on TALF

On Tuesday, May 12, 2020, the Board of Governors of the Federal Reserve System (the “Board”) announced additional details regarding the Term Asset-Backed Securities Loan Facility (“TALF”).  The TALF is a financial crisis-era liquidity facility designed to help meet the credit needs of consumers and businesses by facilitating the issuance of asset-backed securities (“ABS”).… Continue Reading

Federal Reserve Announces Main Street Lending Program and Other Facilities to Provide Credit to Businesses, States, and Municipalities Impacted by COVID-19

Yesterday, the Board of Governors of the Federal Reserve System announced the creation of four new liquidity facilities and the expansion of three previously announced liquidity facilities to provide credit to borrowers impacted by the COVID-19 pandemic. Whereas the previously announced programs primarily targeted certain financial markets and their participants (such as the markets for … Continue Reading

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

Federal Reserve and FFIEC Offer Regulatory Reporting Relief

Earlier this week, the Federal Reserve provided financial institutions with $5 billion or less in total assets a thirty-day extension to the deadline for filing certain first quarter bank holding company financial reports, and the Federal Financial Institutions Examination Council (FFIEC) provided a similar thirty-day extension of the deadline for all institutions (regardless of size) … 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

Federal Reserve Reestablishes Primary Dealer Credit Facility to Support Market Functioning and Facilitate Credit Availability

Yesterday, on March 17, 2020, the Board of Governors of the Federal Reserve System (“FRB”) announced the creation of a Primary Dealer Credit Facility (“PDCF”) to provide a liquidity backstop to primary dealers of the Federal Reserve Bank of New York (“FRBNY”), which include the nation’s largest broker-dealers.  The PDCF will provide short-term loans to … Continue Reading

Federal Reserve Establishes Commercial Paper Funding Facility to Support Flow of Credit to Households and Businesses

Today, on March 17, 2020, the Federal Reserve provided a backstop of commercial paper (“CP”) in the form of a Commercial Paper Funding Facility (“CPFF”) that establishes a special purpose vehicle (“SPV”) to acquire eligible CP directly from eligible issuers.  The CPFF will provide liquidity to CP issuers that may otherwise face issues rolling over … 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

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

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 Reserve Issues Notice of Proposed Rulemaking Regarding Confidential Supervisory Information and FOIA Procedures

On June 14, 2019, the Federal Reserve Board (“Federal Reserve”) released a Notice of Proposed Rulemaking (“NPR”) requesting public comment on updates to its regulations governing the disclosure of confidential supervisory information (“CSI”) and its Freedom of Information Act (“FOIA”) procedures. Although the Federal Reserve classified many of the proposed revisions as “clarifications” or “technical … Continue Reading
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