The OCC finalized a rule clarifying that national trust banks may engage in non-fiduciary activities but left open the question of whether a national trust bank must engage in a minimum a...
The Office of the Comptroller of the Currency issued a notice of proposed rulemaking that would change its supervisory appeals process. We compare the OCC proposal with the recently final...
The OCC proposed a rule that would eliminate any uncertainty as to whether national trust banks can engage in non-fiduciary activities. If adopted, the proposal would align language in th...
The FDIC and OCC propose to codify safety and soundness and reputational risk. This update contains our key takeaways, views on immediate steps banks should consider and a summary of the ...
Davis Polk partner and Financial Institutions practice head Margaret Tahyar, partner David Portilla and counsel Dana Bayersdorfer authored “The state of play for Bank Merger Act applica...
The OCC has reversed recent changes to its bank merger policies through an interim final rule. Our client update is a refresher on the new state of play for Bank Merger Act applications t...
Davis Polk partner Eric McLaughlin and counsel Dana Seesel Bayersdorfer authored Law360’s quarterly New York banking brief in which they summarize the biggest developments in New York b...
The DOJ, FDIC and OCC have revised their bank merger review standards. The new standards are a major shift for bank M&A and will require a careful, detailed analysis to evaluate the viabi...
The FDIC’s proposed amendment to its CIBCA regulations would give the FDIC greater oversight of investments by non-bank investors in holding companies of FDIC-supervised institutions. ...
The FDIC’s proposed brokered deposit rule would expand the definition of deposit broker and eliminate and narrow exceptions. Changes would affect sweep deposit and fintech arrangements.
