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September 25, 2015

The Board of Governors of the Federal Reserve System added two additional questions and answers to its Volcker Rule FAQs. New question number seventeen deals with compliance procedures for market making desks and the identification of covered funds. New question number eighteen discusses CEO certification for prime brokerage transactions.

November 25, 2015

The Board of Governors of the Federal Reserve System ("FRB") will be implementing several recommendations for the enhancement of its internal procedures for supervising large banking organizations. The recommendations follow an extensive review of Reserve Bank procedures for supporting consistent and sound supervisory decisions, as well as methods used by Reserve Banks to resolve differing staff opinions on the supervision of large and complex firms. As a re As a result of the review: i) the FRB will develop policies and practices intended to encourage the exchange of and response to divergent

December 31, 2015
Commentary by Steven Lofchie

The Government Accountability Office ("GAO") reported that community banks, credit unions and industry associations cited an increase in the compliance burden from the Dodd-Frank Act. The GAO report stated that the full impact of the Dodd-Frank Act "remains uncertain because many of its rules have yet to be implemented and insufficient time has passed to evaluate others." The GAO report examined: (i) regulatory analyses by federal agencies and interagency coordination, and (ii) the impact of selected Dodd-Frank provisions and related implementing rules on financial stability. From interviews

January 15, 2016

The Board of Governors of the Federal Reserve System, the FDIC and the Office of the Comptroller of the Currency ("OCC" and, collectively, the "agencies") expressed their support of the March 2014 guidance on the "external audits of banks" by the Basel Committee on Banking Supervision ("BCBS"). While recognizing that the existing practices in the United States are broadly consistent with the BCBS guidance, the agencies also acknowledged that "differences exist between the standards and practices followed in the United States and the principles and expectations" in the BCBS guidance. For that