Financial Services Spotlight

Proposed Fed Guidance for Bank Boards of Directors

Posted by Roy Andersen on Aug 7, 2017 10:05:29 AM

Yesterday the Fed published a proposed guidance document for its expectations for board of directors of banks. The release only applies to the boards of banks with over $50 billion in consolidated assets, but the intent of the Fed is to ease up on directors at all banks. The proposal was issued after an extensive review of the activities of bank boards and reflects independent directors’ dissatisfaction with the burdens that the regulators have been placing on bank directors.

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Topics: Banking, Bank Regulations, Supervision and Regulation, Federal Reserve

Comptroller of the Currency Finalizes Regulation Prohibiting Purchasing Industrial or Commercial Metals

Posted by Roy Andersen on Dec 29, 2016 12:00:00 PM

On December 28, 2016, the OCC posted its final rule to prohibit national banks from dealing in or investing in industrial or commercial metals.[1]  This rule was proposed by the OCC in September 2016, and was approved in substantially the same form as the proposal.

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Topics: Commercial Metals, Purchasing, Banking, Industrial Metals, Copper, National Banks, OCC

Action Required Under the Volcker Rule by January 22, 2017

Posted by Roy Andersen on Dec 14, 2016 12:00:00 PM

Action Required Under the Volcker Rule by January 22, 2017.

Late Monday afternoon, the Fed announced that banks may seek an extension of time (up to five years) to hold and presumably arrange to sell their investments in or holdings of so-called “illiquid funds” that were made impermissible under the Volcker Rule.  Under the most recent relief before Monday, these investments had to be “conformed” or sold by July 21, 2017.  Many banks and banking interest groups had complained to the Fed that a variety of hedge funds and private equity funds were sold and operated to invest in “illiquid” assets and that forced sales of such investments before maturity would be a financial burden.

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Topics: Dodd-Frank, Banking, Illiquid Funds, Investment, Volcker Rule

About the Spotlight


The Financial Services Spotlight examines the regulatory and technology developments impacting banks, asset managers and other financial services providers—where challenges meet opportunities.

 

Meet the Authors


Roy C. Andersen, of counsel in Sullivan & Worcester's New York office, is a member of the Corporate Department. Mr. Andersen focuses on bank regulatory and compliance matters, including international banks and their branches and agencies in New York.

Joel Telpner, partner in the firm's New York office, is a seasoned advisor, strategist and problem solver. Mr. Telpner brings more than 30 years of legal experience in a career that includes time as an AmLaw 100 partner, the former U.S. general counsel of a global financial institution, and a venture capitalist. He is recognized for his ability to deftly manage complex financial transactions, especially those involving sophisticated structured finance and derivatives matters and has an extensive and unique combination of transactional and regulatory experience.

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