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
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
See our article in BAI Banking Strategies, On the Road to Recovery: Phasing in Your Bank’s Recovery Plan, regarding compliance with the OCC’s recovery planning guidance.… Continue Reading
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
