Randall D. Guynn

Davis Polk Discusses OCC’s Risk Governance Guidelines for Banks

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The OCC has proposed a set of enforceable and specific risk governance guidelines to formalize its heightened expectations for large national banks and federal savings associations. The risk governance guidelines would set new, and much higher, minimum standards for the …

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Editor's Tweet: Davis Polk Discusses OCC's Risk Governance Guidelines for Banks

Swaps Pushout Rule: Federal Reserve Banks Revise Discount Window Documentation

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Effective July 16, 2013, the Federal Reserve Banks’ Operating Circular No. 10 (“OC-10”) has been amended to include a new appendix entitledProhibition Against Federal Assistance to Any Swaps Entity (“Appendix 6”).  Appendix 6 is intended …

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Editor's Tweet: Davis Polk on the Swaps Pushout Rule: Federal Reserve Banks Revise Discount Window Documentation http://wp.me/p2Xx5U-1fO

Implications for the CFPB After the D.C. Circuit’s Recess Appointments Decision

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A panel of three judges in the D.C. Circuit stunned Washington on Friday by striking down President Obama’s recess appointments to the NLRB in Noel Canning v. NLRB on a basis much more sweeping than had been anticipated. The two …

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Editor's Tweet: Davis Polk's Tahyar, Yanes, and Guynn discuss the DC Circuit's recent decision in Noel Canning v. NLRB and the Implications for the CFPB.