Companies will be affected in a variety of ways by the receivership of Signature Bank, Silicon Valley Bank or any other similarly situated financial institution. Companies may face difficulty accessing bank facilities or the capital markets or limitations on money market or commercial paper facilities. Resulting liquidity constraints may entail difficult decisions, including prioritizing the
Matthew Bisanz
Virtual Currency Activity Prior Approval Requirement Established by NYDFS
Posted in Fintech, Regulatory
On December 15, 2022, the New York Department of Financial Services (“NYDFS”) issued guidance clarifying that all New York banking organizations are required to obtain prior agency approval for virtual currency-related activity (“2022 Guidance”). The 2022 Guidance is similar to prior notice guidance issued by the federal banking regulators but establishes highly prescriptive information requirements…
SEC Proposes Climate Change Disclosure Rules Applicable to Public Companies
On March 21, 2022, the US Securities and Exchange Commission (SEC) voted 3:1, with only Commissioner Hester Peirce dissenting, to propose long-awaited rules that, if adopted, would require extensive reporting by public companies of climate change-related disclosure and related attestation (the “Proposal”). Comments on the Proposal are due 30 days after publication in the Federal…
Biden Executive Order Calls for Regulatory Proposals on Digital Assets and Central Bank Digital Currency
On March 9, 2022, President Biden signed an executive order titled “Ensuring Responsible Development of Digital Assets” (the “Order”). The Order directs a broad range of federal agencies to recommend legislative and regulatory proposals to foster the development of, and address the risks presented by, digital assets and a central bank digital currency. This Legal…
US Financial Regulators Release Much-Anticipated Report on Stablecoins
On November 1, 2021, the President’s Working Group on Financial Markets (PWG) released its much-anticipated Report on Stablecoins. The Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency joined the PWG in issuing the report, which provides an overview of how stablecoins are created and operate, discusses the risks they present…
Legal Update: Proposed Revisions to Volcker Rule Covered Funds Provisions
On January 30, 2020, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the Commodity Futures Trading Commission proposed revisions to the covered funds provisions of the Volcker Rule. The proposal is intended to address the…
Legal Update: Volcker Rule Revisions Adopted by Agencies
By David R. Sahr, Donald S. Waack, Anna T. Pinedo, Carol A. Hitselberger, Jeffrey P. Taft, Thomas J. Delaney, Marla Matusic & Matthew Bisanz on
Posted in Volcker Rule
The US federal banking and functional regulators (“Agencies”) have finalized revisions to the proprietary trading and compliance program provisions of the Volcker Rule, which implement some, though not all, of the changes that had been proposed by the Agencies in a May 2018 notice of proposed rulemaking. This Legal Update discusses the revisions.