Sky Blog
In October 2023, the FDIC proposed enforceable guidelines on corporate governance and risk management that would apply to all state non-member banks with $10 billion or more in assets.
In early February, several state and national banking trade associations filed suit in U.S. district court in Texas challenging the federal banking agencies’ first comprehensive updates to the regulations implementing the Community Reinvestment Act (CRA) in nearly three decades. Among …
If you follow the financial press, you have probably seen coverage of the new bank capital requirements that federal regulators proposed last year. These rules would strengthen capital levels for the United States’ largest banks and thereby complete the implementation …
Loan accounting in a bank should be straightforward, delivering predictable and transparent results.
While judgment is involved when loan performance deteriorates, the goal of management and outside accountants should be a presentation that maximizes comparability between banks and minimizes idiosyncratic …
The Financial Stability Oversight Council released its 2023 Annual Report, highlighting its 2023 activities, significant financial market and regulatory developments and potential emerging threats to U.S. financial stability. The 2023 Annual Report newly identifies artificial intelligence and insurance as vulnerabilities …
The Dodd-Frank Wall Street Reform and Consumer Protection Act (“DFA”) was signed into law in July 2010. The DFA introduced several reforms; collectively, these reforms were intended to reduce the risk of the financial sector and to provide financial stability …
Bernie Madoff died on April 14, 2021, while incarcerated in the Federal Medical Center in Butner, North Carolina, but he lives on in bankruptcy jurisprudence. The December 2008 disclosure that Bernard L. Madoff Investment Securities LLC (BLMIS) was a Ponzi …
The Financial Stability Oversight Council revised its interpretive guidance and analytic framework for FSOC’s authority to designate nonbank financial companies for Federal Reserve supervision and regulation and to otherwise monitor and respond to financial stability risks. These changes reverse key …
On October 24, 2023, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (together, the “Agencies”) released their final Principles for Climate-Related Financial Risk Management for Large Financial Institutions (the …
On October 11, 2023, the Federal Deposit Insurance Corporation (the “FDIC”) published in the Federal Register for comment a notice of proposed rulemaking to establish new guidelines (the “Proposed Guidelines”) for governance and risk management at FDIC-supervised insured depository institutions …
The Federal Deposit Insurance Corporation (FDIC) has proposed enforceable guidelines on corporate governance and risk management that would apply to all state non-member banks with assets greater than $10 billion (the Proposed FDIC Guidelines). The proposal was issued over two …
On August 29, 2023, US federal banking regulators issued a proposal for long-term debt (“LTD”) requirements for certain midsize and larger US banking organizations (the “LTD Proposal”).1 The LTD Proposal is important because it would require many regional and …
On July 18, 2023, Federal Reserve Vice Chair for Supervision Michael Barr cautioned banks against fair lending violations arising from their use of artificial intelligence (AI). Training on data reflecting societal biases; data sets that are incomplete, inaccurate, or nonrepresentative; …
On July 27, 2023, the federal banking agencies released a lengthy proposal to revise the capital rules applicable to large banks and bank holding companies. The headline news is that the banking agencies expect the proposal to increase capital requirements …
Substantively, banks are pooled investment funds, like mutual funds, exchange traded funds, and so on: They take people’s money and use it to buy financial assets. There is one crucial difference, however. In those other funds, losses are immediately passed …
The recent banking turmoil in the U.S. and Europe has led to calls for greater accountability for bank executives. These include an extraordinary statement from President Joe Biden on the need to hold senior executives accountable for bank failures. Similar …
In a recent paper, we examine whether listed bank holding companies (BHCs) that are small enough to stay private are riskier than private BHCs that are large enough to go public but have opted not to do so.
Some …
The runs on Silicon Valley Bank (SVB) and Signature Bank in March 2023 created a “very high” risk of contagion in the U.S. banking system, according to Treasury Department officials. The intervention by banking regulators, using tools approved in response …
U.S. banking has always been a risky business. The financial panics of 1819, 1837, 1873, 1907, and 1931-32 all sparked banking crises, recessions, or full-scale depressions. Depositors lost everything every time a bank failed. But the Great Depression was the …
Credit Suisse (CS) was sold to UBS on March 19, 2023, to avoid its further deterioration from long-lasting distress and widespread distrust, especially after the collapse of Silicon Valley Bank. The most contentious point of the deal may have been …