With the House expected to vote on a cannabis legalization bill tomorrow, we have updated our visual memorandum to describe the post-election prospects for the three most important cannab...
This deck describes our view of the road ahead for financial regulatory reform under a Biden Presidency and a Republican Senate. We see most of the action coming from the regulators, not...
Last week the Board of Governors of the Federal Reserve System (the Federal Reserve) announced changes to the terms of the Main Street Lending Program (the Program) aimed at boosting smal...
The Office of the Comptroller of the Currency (OCC) has finalized a rule (Final Rule) establishing a bright-line test for determining the true lender of a loan. The Final Rule is intende...
The banking sector is both regulated and supervised, a key difference between banking and the rest of the regulated sectors in the economy. Supervision happens behind the veil of confide...
The Federal Deposit Insurance Corporation (FDIC) has taken another important step to increase transparency and accountability in the supervisory process by proposing amendments to its exi...
The SBA has issued a long-awaited Procedural Notice providing guidance on the procedures for changes of ownership of an entity that has received Paycheck Protection Program funds.This mem...
The OCC has issued an interpretive letter confirming that national banks may take deposits that serve as reserves for fiat currency-pegged stablecoins. The letter continues the series of ...
The SEC has finalized rules that will replace Guide 3, the industry guide for banking organizations. The final rules eliminate a number of the requirements under Guide 3, which now appea...
The Federal Reserve has opened the Main Street Lending Program to nonprofits. Main Street loans are complicated, and the fact that Main Street’s nonprofit lending facilities were bolted...
