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Capital Markets
Lessons Learned from day 1 of non-centrally cleared bilateral repo reporting
The non-centrally cleared bilateral repurchase (NCCBR) market is currently one of the largest of the repo market segments, at an estimated $2 trillion-plus in outstanding commitments each day. On May 6, 2024, the Office of Financial Research (OFR) adopted as final a rule to establish an ongoing data collection for certain non-centrally cleared bilateral transactions in the US repo market.
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Capital Markets
SEC approves FINRA’s Securities Lending 6500 Rule Series
On January 2, 2025, the Securities and Exchange Commission (SEC) approved a rule change to adopt the new Financial Industry Regulatory Authority (FINRA) Rule 6500 Series, also referred to as the Securities Lending and Transparency Engine (SLATE).
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Capital markets
SEC Finalizes daily computation of customer reserve requirements
On December 20, 2024, the Securities and Exchange Commission (SEC) finalized amendments to its Customer Protection Rule (15c3-3) to require carrying broker-dealers to calculate their customer and PAB (proprietary securities account of a broker-dealer) reserve computations daily.
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Banking
Regulatory Management as Strategy: Perspectives on regulatory change management
This is the last of four perspectives we are issuing in our “Regulatory management as strategy” series. This fourth and final edition focuses on regulatory change management (RCM).
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Banking
Federal Reserve Board proposes significant changes to several regulatory reports
The Board of Governors of the Federal Reserve System (FRB) recently published proposals to revise the Consolidated Financial Statements for Holding Companies (FR Y-9C), the Capital Assessments and Stress Testing information collection (FR Y-14Q), and the Report of Selected Money Market Rates (FR 2420).
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Banking
OCC finalizes revisions to its recovery planning guidelines
On October 21, 2024, the OCC finalized revisions to its recovery planning guidelines, codified at 12 CFR part 30, Appendix E (Finalized Guidelines). The Finalized Guidelines retain all the substantive provisions included in the initial proposal with some moderate extension of compliance timelines for new covered banks.
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Banking
Regulatory management as strategy: Perspectives on regulatory remediation
This is the third of four perspectives we are issuing in our “Regulatory management as strategy” series. While this series generally is geared toward more complex and large banking organizations (e.g., Categories I–IV), we believe that many of these practical insights may help inform regulatory engagement by community and regional banks under $100 billion in assets as well.
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Banking
Shifting tides: The future of bank liquidity regulation
Banks are bracing for a series of anticipated changes aimed at enhancing liquidity management and ensuring greater financial stability. These changes, catalyzed by banking failures in spring 2023, underscore the importance of employing appropriate liquidity frameworks to withstand financial stresses.
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Banking
Regulation W: The wall remains
Regulation W compliance is more than just a regulatory requirement—it’s a cornerstone of sound banking practices. Understand its nuances to help improve your risk management strategies and navigate the intricate regulatory landscape with ease and confidence.
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Capital markets
SEC approves changes to Reg NMS to reduce transaction costs and improve market transparency
On September 18, 2024, the Securities and Exchange Commission (SEC) voted to approve several updates to Regulation National Market Securities (Reg NMS) including the minimum pricing increments (i.e., tick size) across all venues, reducing the access fee caps, requiring all fees be known prior to the trade, enhancing the transparency of better priced orders by standardizing round lot and odd lot definitions and providing odd lot pricing in market data.
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Banking
Banking agencies and Department of Justice update their approaches to bank mergers
On September 17, 2024, the FDIC, OCC and DOJ took steps to strengthen oversight of bank mergers, finishing a process that has been in the works for several years. The updates refresh an approach that has been in place since the 1990s, and the changes reflect a modernized banking market (banking consolidation, interstate banking, online banking, among others).
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Banking
FDIC proposes recordkeeping requirements for custodial deposit accounts
On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) Board of Directors unanimously approved a notice of proposed rulemaking (NPR) that would require additional recordkeeping for bank deposits received from third-party, nonbank companies that accept those deposits on behalf of consumers and businesses.
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Banking
So, do you still want to be a bank in 2024?
As the banking industry continues to consolidate, the distinct advantages of banks (e.g., access to payments systems, insured deposits, ability to issue credit and debit cards, and interstate lending) make bank charters an invaluable asset.
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Banking
BCBS issues principles for the sound management of third-party risk
As the banking sector undergoes rapid digitalization, BCBS issued “Principles for the sound management of third-party risk” on July 9, 2024, with a comment period through October 9, 2024.
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Banking
FDIC proposes rules limiting integrated business models of IBs and their parent companies
On July 30, 2024, the FDIC approved a notice of proposed rulemaking to amend Part 354 of the FDIC Rules and Regulations governing parent companies of IBs, which revises part 354 to clarify and enhance the agency’s framework to supervise industrial banks, mitigate risks to the Deposit Insurance Fund, and provide necessary transparency for market participants.
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Banking
FDIC issues proposal on brokered deposit restrictions
On July 30, 2024, the FDIC Board of Directors, by a vote of 3-2, approved a notice of proposed rulemaking that would make several significant revisions to the agency’s rules on brokered deposits (12 CFR 337.6).
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Banking
FDIC approves final guidance to enhance resolution planning at large banks
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) Board of Directors unanimously approved final guidance for Title I Resolution Plan triennial full filers largely as proposed and extended the submission deadline from March 31, 2025, to October 1, 2025.
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Banking
Agencies issue final rule on quality control standards for automated valuation models
On July 17, 2024, six federal regulatory agencies—the Federal Reserve Board of Governors (FRB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA), and National Credit Union Administration (NCUA) (collectively, the Agencies)—issued a final rule to implement quality control standards for AVMs used by mortgage originators and secondary market issuers in valuing those homes.
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Banking
Acting Comptroller Hsu discusses banks’ role in addressing consumer fraud
On July 10, 2024, Acting Comptroller of the Currency Michael J. Hsu discussed the scale of consumer financial fraud and ways financial institutions can better protect consumers from scams, including those stemming from new technologies such as artificial intelligence (AI).
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Banking
Proposed FR Y-14 changes, new data requirements and reporting guidance
The Federal Reserve Board of Governors (FRB) proposed changes to the Capital Assessment and Stress Testing Reports (FR Y-14A, FR Y-14Q, FR Y-14M) on June 21, 2024. These revisions are significant.
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Capital markets
SEC finalizes amendments to Regulation S-P
On May 15, 2024, the Securities and Exchange Commission (SEC) finalized amendments to Reg S-P that modernize the agency’s customer information protection rule, which was initially adopted in 2000.
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Banking
Dodd-Frank Act Stress Test (DFAST) Results June 2024
The Federal Reserve Board (FRB) released the results of the latest Dodd-Frank Stress Test (DFAST) on June 26, 2024. All 31 banks subject to the stress test stayed above their minimum capital requirements in the stress scenario, even with aggregated projection of $685 billion in losses under the hypothetical severe downturn where the banks had more than twice the amount of minimum capital required.
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Banking
Regulatory management as strategy – July 2024
This is the second of four perspectives we are issuing in our “Regulatory management as strategy” series. While this series generally is geared toward more complex and large banking organizations (e.g., Categories I–IV1), we believe that many of these practical tips should help inform regulatory engagement by community and regional banks under $100 billion in assets as well.
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Banking
OCC proposes revisions to its recovery planning guidelines
On June 24, 2024, the Office of the Comptroller of the Currency (OCC) issued a proposal to revise its recovery planning guidelines, codified at 12 CFR part 30, Appendix E (Proposed Guidelines).
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