At the end of April, the Financial Stability Oversight Council (“FSOC”) published for public comment two proposals that would make it easier for FSOC to designate nonbanks as systemically important financial institutions (“SIFIs”).  The proposals, on which public comments are due by June 27, 2023, revise and reverse the designation approach taken during the Trump Administration and are in line…

I. Overview After many months of rapid-fire crypto-related enforcement actions from the SEC, April itself only had one notable complaint, which was filed against Bittrex.  The most important development was not a complaint, but a Wells submission from Coinbase, the largest digital asset exchange in the United States.  Coinbase released publicly its lengthy Wells submission, which calls out the SEC…

The Banking Group of Debevoise & Plimpton LLP has revised the name and expanded the scope of its blog, now titled “The Debevoise FinReg and FinTech Blog.” The revamped client tool will cover a broader range of regulatory topics impacting the financial sector, particularly in the wake of the recent failures of Silicon Valley Bank, Signature Bank and First Republic…

As previewed in our client update from April 26, 2023, three government agencies released reports reviewing the failures of SVB Financial Group (“SVBFG”) and Signature Bank (“SBNY”) on Friday.  Specifically: the Federal Reserve Board (“FRB”) released a report on the failure of SVBFG and Silicon Valley Bank (“SVB”) led by Vice Chair for Supervision Michael Barr (the “FRB Report”); the…

The Silicon Valley Bank (“SVB”) and Signature Bank (“Signature”) failures (together, the “March Failures”) were the second- and third-largest commercial bank failures in U.S. history.  Six weeks after the March Failures, bank stability issues continue to generate headlines, and healthy banks remain subject to depositor outflows.[1]  The March Failures have raised broad-ranging questions regarding the proper calibration of U.S. bank…