The increased emphasis by the prudential banking agencies on recovery planning is evidenced by the Comptroller’s recent publication of a new recovery planning module for the Comptroller...
Davis Polk has submitted a comment letter on the Federal Reserve’s proposed amendments to its guidelines on internal appeals of material supervisory determinations (the Proposal). Whil...
The CRA was put in place over 40 years ago and bears the heavy hand of the woeful history of redlining upon any attempt to change it. But, it is long overdue for a rethink, especially in ...
The Senate passed the Economic Growth, Regulatory Relief and Consumer Protection Act (S.2155) on March 14 by a filibuster-proof vote of 67 – 31. The Senate bill still must pass the Hous...
The Senate has passed the Bipartisan Banking Bill, which would raise the generally applicable statutory threshold for most enhanced prudential standards (EPS) from $50 billion to $250 bil...
Davis Polk partner Margaret Tahyar recently authored “Are Banking Regulators Special?” for The Clearing House’s Banking Perspectives magazine. The article discusses how federal bank...
Davis Polk has submitted a comment letter on the Federal Reserve’s proposed supervisory guidance on board governance (which we summarized in a previous blog post). Consistent with our ...
The question we are being asked most often is whether PHH v. CFPB is headed to the Supreme Court. The D.C. Circuit’s en banc decision that the current structure of the CFPB—an agency ...
The Mulvaney Memo on the CFPB and the rule of law is one of the most remarkable documents to be published by an agency head in many years. It signals a deep commitment to the rule of law...
Vice Chair for Supervision Randal Quarles’ announcement that the Federal Reserve is re-examining its framework for making control determinations under the Bank Holding Company Act is a ...
