This update provides a basic primer on the origins and implications of the major questions doctrine, which has been recently invoked in a 6-3 opinion written by Chief Justice Roberts stri...

Digital asset legislation is on the (perhaps distant) horizon.  We have started to see legislative proposals, some of which are meant to create a regulatory framework for all digital asse...

Custodia Bank has filed suit in federal court against the Board of Governors of the Federal Reserve System and the Federal Reserve Bank of Kansas City, seeking to force a decision on its ...

A recent PWG Report on stablecoins and statements by U.S. financial regulators suggest near-term enforcement focus and longer-term regulatory changes for stablecoin and other cryptocurren...

Federal banking regulators continue to signal their attention to banks’ relationships with third parties, and particularly with fintechs. We think that these developments should be of i...

The Federal Reserve, FDIC and OCC jointly issued proposed guidance on banking organizations’ risk management of third-party relationships. The proposed interagency guidance would replac...

The FDIC announced a modified approach to implementing its insured depository institution (IDI) resolution planning rule for IDIs with $100 billion or more in total assets. Our client upd...

The FDIC has issued a final rule to formalize longstanding expectations it has had for the parent company of a new industrial loan company (ILC).  The FDIC adopted the proposed rule issue...

We have updated our Volcker Rule flowcharts for recent amendments to the covered fund provisions of the Volcker Rule regulations.  These are the second wave of amendments to the Volcker R...

This memo provides our summary of the final rule amending the covered funds portion of the Volcker Rule regulations, which largely adopts the amendments as proposed. We point out the few ...