This update analyzes comments that the FDIC received from a wide range of stakeholders on its corporate governance proposal. Not surprisingly, commenters are overwhelmingly opposed.
The OCC’s proposed changes to its approach to Bank Merger Act applications are a missed opportunity to provide certainty around bank mergers in an uncertain market.
The Federal Reserve OIG issued a report on SVB’s failure. Media reports have described it as nearly identical to the Barr Report. The report is more critical of the supervisory staff. I...
The FDIC, Federal Reserve and OCC have proposed to extend the long-term debt and clean holding company portions of the Federal Reserve’s existing TLAC Rule for U.S. GSIBs and U.S IHCs o...
The majority, concurring and dissenting opinions in Biden v. Nebraska illustrate the differences of view among the Justices on the major questions doctrine.
The Federal Reserve, FDIC and OCC released final joint guidance on banking organizations’ management of risks associated with third-party relationships. The guidance applies to all thir...
The Federal Reserve and the FDIC reports on their supervision of Silicon Valley Bank and Signature Bank provide insight into potential upcoming shifts in regulatory and supervisory focus.
This update provides a basic primer on the origins and implications of the major questions doctrine, which has been recently invoked in a 6-3 opinion written by Chief Justice Roberts stri...
Digital asset legislation is on the (perhaps distant) horizon. We have started to see legislative proposals, some of which are meant to create a regulatory framework for all digital asse...
