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 guide, which was authored by 18 lawyers from the firm’s Antitrust, Banking, Data Strategy and Security, M&A and White Collar Groups, are: Although neither candidate has focused on financial services,…

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 large insured banks under OCC oversight (i.e., national banks, federal savings banks and federal branches). Comments are due on the Proposal 30 days after the date of publication in the…

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 institutions (“IDIs”).[1]  The release finalizes the rule proposal from August 29, 2023 (the “Proposal”). The Proposal was released alongside (i) proposed guidance on resolution planning for section 165(d) holding company…

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”) recovery guidelines (the “Recovery Guidelines”) to all large banks under OCC oversight (i.e., national banks, federal savings banks and federal branches) with at least $100 billion in assets “warrants serious…

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 their Bank Merger Act (“BMA”) review policies, with the FDIC also proposing updates to its supplemental BMA application form.[2]  As to the Federal Reserve Board (“FRB”), at an April 10,…