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Senate Committee Releases Draft of Financial Regulatory Improvement Act

The United States Senate Committee on Banking, Housing and Urban Affairs recently released a draft of the Financial Regulatory Improvement Act of 2015. Among other provisions, this Republican-sponsored legislation would:

  • For institutions that fall within a safe harbor, do away with the annual privacy notice to customers

  • Establish an Office of the Examination Ombudsman at the FFIEC that would be charged with investigating examination complaints

  • Allow an increase from $500 million to $1 billion in regard to banks that can qualify for an 18-month (as opposed to 12-month) examination cycle

  • Exempt from the Volcker Rule banks with assets under $10 billion

  • Allow certain smaller institutions to file less complicated call reports for the first and third quarters

  • Allow smaller banks the protection of a Qualified Mortgage for certain mortgages that are held in portfolio

To view a section-by-section summary, click here.

© 2020 Vedder PriceNational Law Review, Volume V, Number 148


About this Author

James M. Kane, Vedder Price Law Firm, Finance Attorney

James M. Kane joined Vedder Price in 1993 as a shareholder and is a member of the firm’s Financial Institutions Group. From 1981 until joining Vedder Price, he was the district counsel in Chicago for the Office of the Comptroller of the Currency. As the chief legal officer for the Six-State Central District (Illinois, Wisconsin, Michigan, Ohio, Indiana and Kentucky), he was responsible for providing legal and policy advice to the Deputy Comptroller and the 500 examiners of the Central District. In this capacity, he authored opinions on a wide variety of banking law issues and represented...

Daniel C. McKay, Vedder Price Law Firm, Financial Attorney

Daniel C. McKay, II concentrates his practice in the representation of financial institutions and corporations and their officers, directors and shareholders in connection with mergers and acquisitions, securities offerings, corporate finance, corporate governance and regulatory and compliance matters.  He has been involved in more than 150 bank or thrift  mergers and acquisitions/securities offerings, with aggregate consideration of these deals totaling over $50 billion.