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The Dodd-Frank Act contains a management interlocks trap for large banks and financial firms

Winston & Strawn LLP
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USA
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October 8 2010

As financial firms gain experience with the Dodd-Frank Act, the 2,319-page comprehensive financial regulatory reform legislation signed by the president last July, not only are unheralded provisions coming to light, but also subtle indirect consequences of known provisions are also coming to light

Community bank capital and Congress’ antipathy toward credit ratings

Winston & Strawn LLP
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USA
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September 17 2010

Banks have, since 1985, been subject to a risk-based capital regime under which the amount of capital each is to maintain is to be based upon a rough calculation of the amount of risk in the assets on its balance sheet

Regulation of certain wire and ACH transfers to persons abroad is impending in the guise of regulation of consumer “remittance transfers”

Winston & Strawn LLP
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USA
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May 19 2011

The Dodd-Frank Act, a more than 2,300 page comprehensive financial regulatory reform law that the President signed into law last July, contains a number of little known and scantily discussed provisions such as Section 1073 that provides for federal regulation of "remittance transfers," essentially consumer-initiated electronic transfers of funds to persons in foreign countries

Implementing the Durbin Amendment: what was the Fed thinking?

Winston & Strawn LLP
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USA
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April 8 2011

The Federal Reserve Board, on December 16, 2010, approved proposing a rule to implement the Durbin Amendment in the Dodd-Frank Act

New Consumer Financial Protection Bureau asks private contractors to design mortgage disclosure form

Winston & Strawn LLP
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USA
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January 20 2011

The Dodd-Frank Act requires the Consumer Financial Protection Bureau (CFPB) to propose rules and model disclosures that combine the disclosures required under the Truth in Lending Act and Sections 4 and 5 of the Real Estate Settlement Procedures Act

Potential rule change could substantially affect FHLB members and applicants

Winston & Strawn LLP
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USA
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January 27 2011

On December 27, 2010, the Federal Housing Finance Agency (the "FHFA") issued an advance notice of proposed rulemaking ("ANPR") which poses substantial issues regarding certain types of existing members ("Members") of the Federal Home Loan Bank System ("Bank") and certain types of applicants that previously would have qualified for membership

Community banks vs bank examinersare community banks’ concerns about examiner decisions justified?

Winston & Strawn LLP
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USA
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August 25 2011

On August 16, 2011, the U.S. House of Representatives Financial Institution Subcommittee on Financial Institutions and Consumer Credit conducted a hearing into supervision of community banks

Changing landscape: thrift holding companies and their regulator

Winston & Strawn LLP
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USA
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December 30 2011

The Dodd-Frank Act, effective July 21, 2011, eliminated the Office of Thrift Supervision (“OTS”) and transferred its regulatory authority to the Office of the Comptroller of the Currency, the Federal Reserve Board (the FRB), and the Federal Deposit Insurance Corporation

Capital requirements for insurance companies that are savings and loan holding companies and the “Collins amendment”

Winston & Strawn LLP
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USA
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March 9 2012

Insurance companies are subject to state insurance regulation that includes capital requirements generally imposed under uniform regulations based on capital standards adopted by the National Association of Insurance Commissioners (NAIC