In the wake of the financial crisis, mortgage-related reforms enacted as part of the Dodd-Frank Act or established under the Basel capital process have created four different classes of residential mortgage loans that are entitled to some kind of favorable... Read More
The regulatory focus on hedge funds continued during the first quarter of 2012, as new initiatives continued to roll out, and milestones in the implementation of rules put on the books last year were hit. For "large" hedge funds, we see... Read More
Please click on the Attachment: link at the top of the post to view or download the entire article. If Aesop were still in the fable-writing business, and he had been watching the last three years of Dodd-Frank Act rulemaking, we would probably be... Read More
by Edmund "Ed" D. Harllee & Alan B. Clark On Tuesday, June 30, the Consumer Financial Protection Bureau (the “Bureau”) published its final rule in the Federal Register to expand the definition of “larger participants”... Read More
Passage of the landmark Dodd-Frank Wall Street Reform and Consumer Protection Act, the most far-reaching financial regulatory legislation since the Great Depression, has set the stage for major adjustments in the financial services industry. The Act impacts... Read More
On May 20, 2010, the Senate passed the "Restoring American Financial Stability Act of 2010" as amended ("Senate Bill"). Congressional leadership has indicated that conference committee proceedings will take place in June, making it... Read More
by Robert J. Pile and Heather J. Howdeshell TCF National Bank (TCF) has filed a suit in the United States District Court in South Dakota challenging the constitutionality of Section 1075 of the Dodd-Frank Wall Street Reform and Consumer Protection Act... Read More
Just to keep you on your toes if you have less than $150 million under management, states are now filling in the gaps left by Dodd-Frank. If you are under that threshold, you lose the ability to register with SEC and now have to look to at being regulated... Read More
Shortly before year-end, the Federal Reserve Board ("FRB") proposed several rules to manage systemic risks presented by bank holding companies with consolidated assets of $50 billion or more and by nonbank financial institutions that are designated... Read More
You would expect that a publication with a libertarian tilt like The Economist would not look favorably at the Dodd-Frank Wall Street Reform and Consumer Protection Act . They call it Too big not to fail . Being The Economist , the article argues with... Read More
by Kay Gordon and Joshua M. O'Melia Excerpt: I. Introduction On May 10, 2011, as required by Section 418 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"), the U.S. Securities and Exchange Commission... Read More
Five federal regulatory agencies — the SEC, CFTC, the Board of Governors of the Federal Reserve System, the Office of the Comptroller and the FDIC — implemented the 900 plus page Volcker Rule. Many consider the Volcker Rule to be the center... Read More
Excerpt: On Monday, March 15, 2010, Senate Banking Committee Chairman Chris Dodd (D-CT) released a Chairman's Mark of the "Restoring American Financial Stability Act of 2010" (the "Bill"). The Bill, which has been in development... Read More
Contingency Planning in the Absence of a Regulatory Structure This memorandum first explains the July 16, 2011 problem that will arise because the Dodd-Frank derivatives legislation (Title VII of the statute) goes into effect without either a ready... Read More
by Dan Crowley, Karishma Shah Page, Bruce Heiman, Collins R. Clark and Justin D. Holman Excerpt: On December 11, the House of Representatives passed H.R. 4173, the Wall Street Reform and Consumer Protection Act of 2009 (see H.R. 4173 as introduced... Read More