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On Thursday, April 19, 2012, the Federal Reserve Board issued a policy statement clarifying the manner in which the Volcker Rule prohibitions would apply and would be enforced during the statutory two-year Conformance Period.  Despite public statements by...

On December 20, 2011, the Federal Reserve proposed regulations to implement the enhanced prudential standards mandated by Section 165 and the early remediation requirements mandated by Section 166 of the Dodd-Frank Wall Street Reform and Consumer Protection Act...

On Tuesday, October 11, the Federal Reserve and the Federal Deposit Insurance Corporation (the "FDIC") unveiled proposed regulations to implement the Volcker Rule (the "Proposed Regulations") that will be issued jointly by the Federal Reserve, the FDIC, the Office...

Regulators continue to work on developing more effective tools for resolving failed banks and other systemically important financial institutions. The aim is to put an end to the idea that any institution is "too big to fail" and so can depend on taxpayer...

Many experts have said that a determination of systemic significance requires an understanding of a wide range of characteristics of a financial institution and its business. Nonetheless, the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank...

On January 18th, 2011, the Financial Stability Oversight Council (the "Council") published a Study & Recommendations on Prohibitions on Proprietary Trading & Certain Relationships with Hedge Funds & Private Equity Funds (the "Study")....