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 ...
Recent Supreme Court decisions show a strong and continued rebalancing of power in the administrative state that has been years in the making. This update outlines what it means for the f...
Addressing climate change is one of the highest priorities of the Biden Administration, and recent legislation in the United States means that regulatory action by the banking and other a...
The Executive Order on Climate-Related Financial Risk is the latest significant step by the Biden Administration to analyze and mitigate the risks that climate change poses to the U.S. ec...
A recent guilty conviction, after a jury trial, shows how complex and fraught the zigzag path to marijuana legalization is in the payments space. At a time when the federal government has...
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...
Davis Polk has prepared two memos describing key portions of the bill just signed into law: the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). In this memo, we cover the...
