On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions and would dramatically expand the number of deposit brokers and the amount of deposits that are brokered. Listen to our podcast to understand what this rollback will mean
Matthew Bisanz
The Pendulum Swings Back: FDIC Proposes Changes to Brokered Deposits Restrictions
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed revisions to the restrictions on brokered deposits (the “Proposal”). The Proposal is intended to strengthen the restrictions to reflect the FDIC’s experience since earlier revisions in 2020 and the regional bank failures of 2023. This is generally accomplished by undoing key elements of the…
FSB Raises Concerns With CP and CD Markets
The Financial Stability Board (FSB) recently issued a report on vulnerabilities in the markets for commercial paper (CP) and negotiable certificates of deposit (CDs). The report analyzes the structure of the markets, identifies vulnerabilities, and suggests reforms that policy makers might consider. It acknowledges that limitations exist, and, therefore, the adoption of the reforms will…
SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers
On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the “CIP Proposal”) that would apply customer identification program obligations to SEC registered investment advisers and exempt reporting advisers. In this Legal Update, we provide…
MB Microtalk: The SEC’s Climate-Change Disclosure Rules: REG S-X Changes
In this MB Microtalk video, discussing the SEC’s final climate-change disclosure rules, Mayer Brown’s Matt Bisanz provides an overview of the changes made by the final rules to Regulation S-X, which require a company to include certain climate-related financial statement metrics and related disclosures in a note to its audited financial statements.
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SEC Adopts Climate Change Disclosure Rules Applicable to Public Companies and Offerings
The Securities and Exchange Commission (the “SEC”) has adopted new rules that require public companies to disclose substantial information about the material impacts of climate-related risks on their business, financial condition, and governance (the “Final Rules”). The SEC says that “climate-related risks, their impacts, and a public company’s response to those risks can significantly affect…
Comment Period for Basel III Endgame Proposal Closes
On January 16, 2024, the comment period closed for the US banking regulators’ Basel III Endgame proposal. Nearly 200 comment letters were submitted from the financial sector, commercial user, and the general public.
Mayer Brown has been actively engaged on this important rulemaking. We have helped clients draft numerous comment letters, including for the…
Market Risk Considerations Under the US Basel Endgame Proposal
While the recent US Basel Endgame proposal will affect many elements of the capital rules, it will have a particularly significant effect on market risk, where it may increase the capital requirement by more than 50%. Midsize and larger US banking organizations and others with significant trading activity also will need to develop extensive position…
Cart Before Horse: Banking Regulators Extend Comment Period and Launch Data Collection for Basel Endgame
On October 20, 2023, the US federal banking regulators announced that they were extending the period for public comment to January 16, 2024 for both the (i) Basel Endgame proposal to significantly revise the risk-based regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and (ii) proposal to change the…
Corporate Governance Standards Proposed by FDIC
On October 3, 2023, the Federal Deposit Insurance Corporation (“FDIC”) proposed standards for corporate governance and risk management for the institutions it regulates that have $10 billion or more in total assets. The proposed standards would establish extensive and rigid requirements for a wide range of state-chartered banks and reverse decades of reliance on state…