Gregory J. Lyons – Debevoise FinReg and FinTech Blog

Reg Reform

U.S. Election 2024: Financial Services Outlook

By: Gregory J. Lyons, Andrew J. Ceresney, Satish M. Kini, Helen V. Cantwell, Charu A. Chandrasekhar, Courtney Dankworth, Erez Liebermann, Gordon Moodie, Jeffrey L. Robins, Kristin A. Snyder, Caroline Swett, Ted Hassi, Patrick Fuller, Chen Xu, Ben Collins-Wood, Alexandra N. Mogul, Taylor Richards and Brynn D'Avanzo November 4, 2024

Debevoise & Plimpton LLP has published a guide to the potential impact of the U.S. election on the financial services industry, including possible regulatory implications. The key takeaways from the…

Recovery Planning

OCC Proposes Expanding Recovery Plan Guidelines to Banks with $100 Billion or More

By: Gregory J. Lyons, Elie J. Worenklein and Jonathan Steinberg June 27, 2024

On June 24, 2024, the Office of the Comptroller of the Currency (the “OCC”) issued a notice of proposed rulemaking (the “Proposal”) that would amend its recovery planning guidelines for…

Recovery Planning

FDIC Finalizes Rules Revamping IDI Resolution Plan Requirements

By: Gregory J. Lyons, Elie J. Worenklein and Jonathan Steinberg June 24, 2024

On June 20, 2024, the Federal Deposit Insurance Corporation (“FDIC”) issued a final rule comprehensively restating and expanding its resolution planning rule (the “IDI Rule”) applicable to large insured depository…

Recovery Planning

Acting Comptroller Hsu Hints at Expanding OCC Recovery Plan Guidelines to Banks with $100 Billion or More

By: Gregory J. Lyons, Elie J. Worenklein and Jonathan Steinberg June 3, 2024

In a speech on May 27, 2024, Acting Comptroller of the Currency, Michael J. Hsu, stated that expanding the application of the Office of the Comptroller of the Currency’s (“OCC”)…

Supervision

The FRB Proposes its Approach to More Rigorous Bank Merger Review

By: Gregory V. Gooding, Ted Hassi, Morgan J. Hayes, Matthew E. Kaplan, Gregory J. Lyons, Ben Collins-Wood, Tejas Dave, Clare K. Lascelles, Alexandra N. Mogul, Adam Saunders and Gabriela Urias May 16, 2024

As detailed in our recent Debevoise in Depth articles,[1] both the Office for the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Cooperation (“FDIC”) have proposed changes to…

Resolution Planning

FDIC Report Expresses Confidence in GSIB Resolution, May Affect Large Regional Bank M&A Prospects and Strategy

By: Gregory J. Lyons, Jeffrey L. Robins, Elie J. Worenklein, Tejas Dave, Ezra Newman and Gabriela Urias May 14, 2024

Introduction On April 10, 2024, the Federal Deposit Insurance Corporation (the “FDIC”) released a report regarding Title II of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank…

Capital

The FDIC Proposed Supplement to the Bank Merger Act Application Form

By: Gregory V. Gooding, Ted Hassi, Morgan J. Hayes, Matthew E. Kaplan, Gregory J. Lyons, Tejas Dave, Clare K. Lascelles, Alexandra N. Mogul and Gabriela Urias April 23, 2024

Hundreds of hours’ worth of changes and additions proposed for applicants On March 21, 2024, the Federal Deposit Insurance Corporation (“FDIC”) published a proposed update to its Statement of Policy…

Congressional Hearings

Financial Regulators Emphasize Focus on Non-Bank Financial Stability Risks, Technology-Related Risks

By: Gregory J. Lyons, Avi Gesser, Taylor Richards, Tzerina Dizon and Tara R. Holzer February 22, 2024

Financial regulators continue to focus their attention on financial stability risks, particularly in the non-bank sector, suggesting Financial Stability Oversight Council (“FSOC”) powers could be deployed to address these risks. …

Capital

Acting Comptroller Previews Changes to Liquidity Regulations

By: Gregory J. Lyons, Chen Xu and Tejas Dave January 25, 2024

Acting Comptroller of the Currency Michael Hsu recently gave a speech previewing potential changes to the federal banking agencies’ liquidity regulations. Specifically, he discussed recalibrating the outflow rates for uninsured…

Fintech