In the Winter 2018 issue of Supervisory Insights, the FDIC provided information to help financial institution management navigate a potential transition away from LIBOR. In an article titled "Transitions in Financial Instrument Reference Rates," the FDIC advised institutions to go beyond simply selecting interest rates and instead to focus on evaluating the impact of the risks associated with a potential transition in reference rates with regard to areas such as information technology, management information systems and accounting, among others. In addition, the FDIC noted, there are "no plans
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Martha Miller, Director of the Office of the Advocate for Small Business Capital Formation (the "Office"), explained that the recently established Office is intended to help small businesses and their investors access capital. In remarks at the Kauffman Foundation's "1 Million Cups" program held in Kansas City, Missouri, Ms. Miller said the Office will, in part, focus on assisting small businesses in resolving issues with the SEC and self-regulatory organizations, and on identifying problems faced by women- and minority-owned small businesses. As to "who" qualifies, Ms. Miller noted that
SIFMA, the Institute of International Bankers, the American Bankers Association and others ("trade associations") urged the U.S. House Committee on Financial Services (the "Committee") to amend the "outdated" and "inefficient" Bank Secrecy Act ("BSA") regulatory framework. In addition, the trade associations called for the Committee to create a federal registry of the beneficial owners of legal entities. The trade associations noted that the BSA regulatory framework is nearly 50 years old and "has not fundamentally changed since its adoption in 1970." The trade associations stated that the
The Consumer Financial Protection Bureau ("CFPB") provided an overview of servicemember complaints (i) related to financial products and (ii) listed by state.
ISDA, SIFMA, the American Bankers Association, the Bank Policy Institute and the FIA (collectively, the "Associations") commented on a proposal of U.S. banking regulators (see here for coverage) to implement the "standardized approach for counterparty credit risk" ("SA-CCR") by U.S. capital rules. The Associations raised concerns over the potential impact of the proposed rule on the derivatives market, specifically equity and commodity derivatives. The Associations expressed general support for the move from the "current exposure method" to a more risk-based measure, but found that elements of