Debevoise & Pimpton FinTech Blog

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By: Debevoise & Plimpton

Blog Authors

Abarone
Chenxu
Cnswett
Joshua González
Alison M. Hashmall
Ezra Newman

Latest from Debevoise & Pimpton FinTech Blog

On February 28, 2024, U.S. President Joe Biden signed Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern” (the “Order”). Concurrently with the issuance of the Order, the U.S. Department of Justice (“DOJ”) released an Advance Notice of Proposed Rulemaking (“ANPRM”) that discusses…

On March 6, 2024, the U.S. Securities and Exchange Commission (“SEC”) adopted a long-awaited final rule, The Enhancement and Standardization of Climate-Related Disclosures for Investors, which will require registrants, including foreign private issuers (“FPIs”),[1] to disclose extensive climate-related information in their registration statements and periodic reports (the “Final Rule”). The Final Rule is intended…

Financial regulators continue to focus their attention on financial stability risks, particularly in the non-bank sector, suggesting Financial Stability Oversight Council (“FSOC”) powers could be deployed to address these risks.  Nonbank financial institutions (“NBFI”) and technology-related risks, particularly those related to artificial intelligence (“AI”), were key areas of focus in this month’s Congressional hearings with…

On February 6, 2024, the U.S. Securities and Exchange Commission (the “Commission”) adopted new rules 3a5-4 and 3a44-2 (collectively, the “Final Rules”), under the Securities Exchange Act of 1934 (the “Exchange Act”) further defining the phrase “as a part of a regular business” as used in the statutory definitions of “dealer”[1] and “government securities…

Acting Comptroller of the Currency Michael Hsu recently gave a speech previewing potential changes to the federal banking agencies’ liquidity regulations.  Specifically, he discussed recalibrating the outflow rates for uninsured deposits in the current liquidity coverage ratio (“LCR”) and introducing a new five-day stressed liquidity requirement.  In addition, and to complement potential changes to the…

Key Takeaways:

  • In the final quarter of 2023, the Financial Stability Oversight Council (“FSOC”) issued its 2023 Annual Report, a new analytic framework for financial stability risks (the “Final Analytic Framework”) and final guidance on its nonbank financial company determinations process (the “Final Guidance”). The 2023 Annual Report, among other things, highlights areas of risk

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Over the past few months, U.S. federal banking regulators have issued a number of proposals aimed at enhancing capital and long-term debt requirements for both U.S. GSIBs and large regional banks. Banks have a range of financing options available to satisfy both existing and potential requirements. This Debevoise InDepth explores the myriad of options available…

On October 11, 2023, the Federal Deposit Insurance Corporation (the “FDIC”) published in the Federal Register for comment a notice of proposed rulemaking to establish new guidelines (the “Proposed Guidelines”) for governance and risk management at FDIC-supervised insured depository institutions (i.e., state non-member banks) with $10 billion or more in consolidated assets (“covered institutions”). The Proposed…