Sky Blog
In a significant step towards modernizing Bank Secrecy Act compliance, FinCEN and certain banking agencies are providing flexibility in “know your customer” requirements for banks.
The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), …
Climate change has become a central topic of discussion among banking regulators and policymakers. While many policymakers focus primarily on addressing the environmental externalities associated with carbon emissions, banking regulators confront a unique set of challenges that the current regulatory …
The U.S. Federal Reserve is 12 banks, not one. Each serves a different region of the country and brings insights from that region into the process of formulating nationwide monetary policy. Each also provides a variety of banking services to …
Venture capital contracting is the function of a complex private-ordering exercise through which venture capitalists and entrepreneurs address the challenges of financing high-tech firms (Kaplan & Strömberg, 2004). Throughout decades of iterative practice, U.S. venture capital contracts have …
The OCC has reversed recent changes to its bank merger policies through an interim final rule. Our client update is a refresher on the new state of play for Bank Merger Act applications to the OCC, which is a return …
In April 2025, the landscape of U.S. crypto regulation shifted significantly. Three of the country’s principal bank regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – jointly …
Over recent decades, the massive globalization of finance has led many observers to expect widespread harmonization of nations’ financial regulations. Yet, while there has been a remarkable degree of harmonization in some areas, at least at the regional level, considerable …
The Federal Deposit Insurance Corporation (FDIC) is the U.S. agency responsible for insuring all bank deposits and facilitating all bank resolutions. Yet, as only one of three bank regulators, the agency relies on the Federal Reserve (Fed) and Office of …
Policymakers around the world have typically outsourced the detection of financial crime to the private sector. This approach is often referred to as the “gatekeeper” model, with the basic idea being that private firms, like bodyguards at a nightclub, are …
In late November 2024, the Bank of England published the results of its first system-wide exploratory scenario (SWES) exercise – a year-long effort to model how various financial entities, including non-bank financial intermediaries (NBFIs) and banks, would respond to a …
New bank formation in the United States is at an all-time low, and Americans increasingly rely on non-bank financial technology companies (fintechs) to satisfy their financial services needs. Fintechs that do not operate through banks mostly operate outside the direct …
A well-trodden path for banks to achieve regulatory capital reductions by mitigating credit risk is through a synthetic securitization, either by issuing credit-linked notes (CLNs)1 or engaging in bespoke bilateral credit derivative transactions. These transactions—while complex to execute—offer the …
Bank stocks surged the day after Donald J. Trump won election to a second presidential term, recording double-digit gains on a widespread view that financial regulation under the new administration will be more industry friendly than in the current one. …
I teach a course on “Financial Crises/Regulatory Responses” with the economist Patrick Bolton. This course addresses the struggle to establish and maintain financial stability, an apex goal of the financial system. Last week, I told the students that by the …
The announcement by Denver-based FirstSun Capital Bancorp and Seattle-based HomeStreet, Inc. on October 29 that the Federal Reserve and the Texas Department of Banking had asked them to withdraw their applications for approval of their pending merger illustrates the potential …
Given banks’ importance to global economic stability, how they manage liquidity – their capacity to transform short-term liabilities into long-term assets – plays a pivotal role in supporting growth while maintaining financial resilience. It also entails considerable risk. Creating more …
On October 9, 2024, the Commerce Department’s Bureau of Industry and Security (BIS) issued new guidance for financial institutions on best practices for compliance with export control laws and regulations (the Guidance).[1] The Guidance caps a series of notes …
The DOJ, FDIC and OCC have revised their bank merger review standards. The new standards are a major shift for bank M&A and will require a careful, detailed analysis to evaluate the viability of any proposed transaction.
The Federal Deposit …
We have argued that bank regulators should disclose more bank information than is now required.[1] This is because supervisory practices generally do little to promote transparency, which leads to opacity that interferes with the pricing of risk and undermines …
The Federal Deposit Insurance Corporation (FDIC) recently proposed and published a Federal Register notice for a proposed rule that would revise the agency’s Change in Bank Control Act (CIBCA) regulations. Specifically, the proposed rule would add a second layer …