Facing Unexpected Events In The US Financial Markets: Advice For Regulated And Unregulated Entities

US and global regulators are once again focused on having market participants design and implement business continuity and disaster recovery (BCDR) plans, as well as corresponding policies and procedures. This renewed focus is not solely in response to the disruption caused by the coronavirus (COVID-19) pandemic to markets, business and society, as plenty of events in the last two decades have proved that market participants should expect the unexpected. While it can be incredibly […]

By | September 20th, 2022 ||

Federal Reserve Clarifies Access To Master Accounts And Services For Financial Institutions, Including For “Novel Charters” In Final Guidelines

The Federal Reserve Board (“FRB”) has approved final guidelines (“Final Guidelines”) for Federal Reserve Banks (“Reserve Banks”) to use in evaluating requests for master accounts and access to Reserve Bank financial services (“Fed Accounts and Services”).1 The Final Guidelines reflect the comments to and development of two prior proposed guidelines: (i) the initial proposed guidelines, issued on May 11, 2021; and (ii) the supplemental proposed guidelines, issued March 8, 2022 (please see our prior Client […]

By | September 15th, 2022 ||

In Depth: Summary Of Notable Comments To Federal Banking Agencies’ Interagency Proposal To Update Community Reinvestment Act Rules

As we reported in May, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a notice of proposed rulemaking to amend and update the rules implementing the Community Reinvestment Act (“CRA”). The comment period on the proposal ended on August 5. We held off summarizing the comments until most people returned from, hopefully, some restful end-of-summer R&R.

Summary of the Proposal

The proposal […]

By | September 13th, 2022 ||