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...
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...
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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...
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”...
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...
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
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...
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...
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...
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...
by Kay Gordon and Joshua M. O'Melia
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...
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...
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...
Contingency Planning in the Absence of a
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...
by Dan Crowley, Karishma Shah Page, Bruce Heiman, Collins
R. Clark and Justin D. Holman
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...