November 18, 2019
On October 29, 2019, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the “Federal Agencies”) adopted a final rule to simplify the regulatory capital requirements for eligible community banks and holding companies that opt into the community bank leverage ratio framework (“CBLR framework”), as required by Section 201 of the Economic Growth, Relief and Consumer Protection Act of 2018. The final rule will be effective as of January 1, 2020.
Read More...
October 31, 2019
Read More...
September 26, 2019
To our clients and friends:
The U.S. House of Representatives approved its version of the SAFE Banking Act of 2019 yesterday. The legislation would create a safe-harbor for banks, thrift and credit unions to provide financial products and services to state-licensed cannabis businesses and their service providers.
The legislation also directs the federal banking regulators to jointly issue guidance on the legality of providing financial products and services to businesses that sell hemp, hemp-derived CBD and hemp-derived cannabinoid products.
The attached Alert summarizes the key provisions of the legislation.
Read More...
June 19, 2019
To our clients and friends:
The Securities and Exchange Commission recently proposed amendments to its definitions of “accelerated filer” and “large accelerated filer.” The attached newsletter provides a review of the proposed changes and discusses how those changes would affect public companies’ periodic reporting with the SEC.
Read More...
June 6, 2019
To our clients and friends:
On May 24, 2019, the Office of the Comptroller of the Currency (“OCC”) issued its final rule (which becomes effective July 1, 2019) to allow a federal savings association with total consolidated assets of $20 billion or less as of December 31, 2017 to elect to operate with national bank powers without converting to a national bank charter. This election would allow an eligible federal savings association to exceed its statutory commercial and consumer lending limits and avoid compliance with the qualified thrift lender test.
While the final rule is welcome news for federal savings associations, significant interpretative questions remain as to how it may be utilized by a federal savings association subsidiary of a stock or mutual holding company. Specifically, the final rule does not address whether a subsidiary savings association of a savings and loan holding company that elects to operate with national bank powers would still be required to satisfy the qualified thrift lender test, which is a statutory requirement applicable to savings and loan holding companies. The OCC recognizes this issue and has directed all interpretative questions to the Federal Reserve. We have discussed this with the Federal Reserve Board staff and they are currently reviewing the final rule and its possible impact on savings and loan holding companies. However, they have not provided further guidance on this issue.
For more information, including a summary of the OCC’s final rule, please see the attached News Alert.
Read More...
