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Federal Reserve Releases Regulatory Agenda

Today the Federal Reserve issued its semiannual regulatory flexibility agenda for fall 2017, which lists regulatory matters the agency anticipates having under consideration during the period from November 1, 2017 through April 30, 2018.

The agenda is notable in two respects.  First, the Federal Reserve anticipates issuing, together with the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation, a proposed rule to implement the “source of strength” requirement of section 616(d) of the Dodd-Frank Act by September 2018.  Section 616(d) requires that any bank holding company or savings and loan holding company serve as a source of financial strength for any depository institution that it controls, and that any other company that controls an insured depository institution serve as a source of strength for such an institution.  Under section 616(d), the agencies were supposed to have issued an implementing rule no later than July 21, 2012.

Second, the agenda does not list a final rulemaking for the Net Stable Funding Ratio (“NSFR”) rule.  The federal banking agencies proposed the NSFR in May 2016, when the agencies were led by appointees of President Obama.  The NSFR’s absence on the Federal Reserve’s agenda suggests that the agencies – now led by appointees of President Trump in the case of the Federal Reserve and the OCC – may need additional time to determine how they intend to finalize the rule, if at all.

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About this Author

Randy Benjenk, Covington Burling, Regulatory attorney
Associate

Randy Benjenk helps clients navigate the bank regulatory landscape. He represents domestic and foreign financial institutions and trade associations on a variety of bank regulatory issues, including compliance, government affairs, and transactional matters.

Mr. Benjenk regularly advises clients on compliance with provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Bank Holding Company Act, the Change in Bank Control Act and U.S. and international capital and liquidity regulations.

Mr. Benjenk represents financial institutions...

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