On July 6, the Federal Reserve Board ("FRB"), the FDIC and the Office of the Comptroller of the Currency detailed an interim approach to rules and reporting requirements jointly administered by the agencies that are impacted by the enactment of the Economic Growth, Regulatory Relief, and Consumer Protection Act (the "Relief Act").
This interim approach affects company-run stress testing, resolution plans, the Volcker rule, high volatility commercial real estate exposures ("HVCRE"), examination cycles, municipal obligations as high-quality liquid assets ("HQLA"), and other provisions of the Relief Act. It will apply until agency rules are amended to implement the changes provided for in the Relief Act.
In a separate statement, the FRB described additional requirements that certain smaller, less complex banking organizations will be exempt from in accordance with the Relief Act.
Cadwalader partners summarized key provisions of the Economic Growth, Regulatory Relief, and Consumer Protection Act.
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