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.
On June 30, President Biden signed the resolution to repeal the OCC’s true lender rule from the Trump administration. With majority votes from the House and the Senate, the rule has bee...
The Office of the Comptroller of the Currency (OCC) has finalized a rule (Final Rule) establishing a bright-line test for determining the true lender of a loan. The Final Rule is intende...
As Acting Comptroller Brian Brooks promised in his Statement on Becoming Acting Comptroller, the OCC proposed a rule on July 20, 2020, setting forth standards for determining the true len...
On his first day in office, Acting Comptroller of the Currency Brian Brooks finalized a proposed regulation that codifies the valid-when-made principle, that a loan that is legally origin...
There are distinct, but subtle, shifts in tone in the FSOC’s 2017 Annual Report, especially when compared to previous annual reports and read together with three recent Treasury reports...
The Trump Treasury Department’s vision for how the FSOC should fulfill its mission is emerging.[1] Ironically, this new, and we think better vision, may be closer to how the Obama Trea...
