Cleary Gottlieb Discusses New Law Revising Dodd-Frank Act

The Economic Growth, Regulatory Relief, and Consumer Protection Act (the “Act”), which became law on May 24, contains the first major package of revisions to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.  The Act leaves the architecture and core features of Dodd-Frank intact but significantly recalibrates applicability thresholds.  While the changes mandated by the Act are significant, it also places significant discretion for further changes in the hands of the Federal Reserve Board.

Both the House of Representatives and the Senate passed the Act on bipartisan votes.  The Chairman of the House Financial Services … Read more

Cleary Gottlieb discusses Shortcomings in Financial Company Resolution Plans

On August 5, 2014, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation (the “Agencies”) released a Joint Statement identifying common shortcomings and action steps for the 11 largest financial companies that initially filed resolution plans in 2012 (the “First Wave Filers”).[1] Contemporaneously with the Joint Statement, the Agencies sent letters to each of the First Wave Filers in which they identified more detailed and specific shortcomings in individual First Wave Filers’ 2013 resolution plans and additional information required for the 2015 plans (the “Joint Letters”).

In effect, the Joint Statement and the Joint … Read more