Posts by Bill Hoisington

REGULATORY DEVELOPMENTS New Federal Advisory Committee on Insurance On May 9, Treasury announced that it is creating the Federal Advisory Committee on Insurance (FACI) to advise the Federal Insurance Office (FIO) and Treasury.  This new Committee comes after consistent criticism by members of Congress, the National Association of Insurance Commissioners (NAIC), and various insurance trade…

REGULATORY DEVELOPMENTS New Guidance on Model Risk Management On April 4, the Office of the Comptroller of the Currency (OCC) adopted new supervisory guidance developed with the Federal Reserve Board to replace Bulletin OCC 2000-16, “Model Validation.”  The new guidance incorporates a broader scope of model risk management.  A central principle is the need for “effective…

REGULATORY DEVELOPMENTS FDIC NPR Implementing Certain Liquidation Authority Provisions of Dodd-Frank On March 15, the Federal Deposit Insurance Corporation (FDIC) issued a notice of proposed rulemaking (NPR) implementing certain orderly liquidation authority provisions of the Dodd-Frank Act.  Dodd-Frank gives the FDIC broad authority to use receivership powers to liquidate failing systemic financial firms in an…

REGULATORY DEVELOPMENTS Federal Reserve Board Approves Final Volcker Conformance Period Rules On February 9, the Federal Reserve Board announced its approval of a final rule to implement the provisions of the Dodd-Frank Act that give banks a period of time to conform their activities and investments to the prohibitions and restrictions of the so-called Volcker…

REGULATORY DEVELOPMENTS FSOC Volcker Rule Study As covered in an Ad Hoc LRA earlier this month, the Financial Stability Oversight Council (FSOC) issued its long-awaited study and recommendations to the federal banking agencies regarding implementation of the Volcker Rule. The study recognized the concern that separate account products could be included in the definitions of “hedge…

REGULATORY DEVELOPMENTS Joint Agency Proposal to Set Risk-Based Capital Floor The federal banking agencies are seeking comment on their interagency proposal to implement certain provisions of Section 171 of the Dodd-Frank Act, commonly known as the Collins Amendment.  Section 171 provides that the capital requirements generally applicable to insured banks will serve as a floor…

REGULATORY DEVELOPMENTS FSOC Requests Comment on Implementation of Volcker Rule As previously covered in the October LRA and an Ad Hoc LRA (sent 11/11/10), we have been providing updates regarding the implementation of the Volcker Rule and the Financial Stability Oversight Council’s (FSOC’s) forthcoming study and recommendations on the subject.  A number of trade associations…

REGULATORY DEVELOPMENTS FSOC Requests Comment on Implementation of Volcker Rule The Dodd-Frank Act established the Financial Stability Oversight Council (FSOC) to identify threats to the financial stability of the U.S., promote market discipline, and respond to emerging risks to the stability of the U.S. financial system.  The FSOC held its first meeting on October 1. …

REGULATORY DEVELOPMENTS Dodd-Frank Act – Hedge Fund/Private Equity Fund Definition Section 619 of the Dodd-Frank Act addresses bank prohibitions on proprietary trading (commonly referred to as the Volcker Rule) and restrictions on banks relationships with hedge funds and private equity funds. The Act defines hedge funds and private equity funds to mean an issuer that…