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The Office of the Comptroller of the Currency updated the "Recovery Planning" booklet of the Comptroller's Handbook. The handbook covers examination procedures. The revised version of the booklet replaces and rescinds the first version. The updates to the booklet include changes to the enforceable guidelines with respect to recovery planning standards for covered national banks, federal savings associations and federal branches. In particular, (i) the average total consolidated assets threshold for applying the guidelines to banks is increased from $50 billion to $250 billion and (ii) the

SEC Director of the Division of Corporation Finance William Hinman underscored the importance of providing specific disclosure on issues such as Brexit risk and sustainability. In remarks at the Annual Institute on Securities Regulation in Europe, Mr. Hinman said that companies that provide generic disclosures ( i.e., that Brexit presents a risk and that the outcome is unpredictable) fail to disclose adequately to investors the specific potential impact of such risks. Mr. Hinman identified questions that the SEC will consider when assessing Brexit-related disclosure in 2018 annual reports: "Is

The U.S. Treasury Department ("Treasury") Office of Foreign Assets Control ("OFAC") extended the expiration date of a General License ("GL") involving PDV Holding, Inc. ("PDVH") and CITGO Holding, Inc. ("CITGO"). GL 7A, which replaces GL 7, authorizes certain transactions and activities prohibited by Executive Order 13850 as they relate to PDVH, CITGO and any of their subsidiaries. GL 7A replaces the July 27, 2019 expiration date in paragraph (a) of GL 7 with an 18-month authorization that renews automatically on a monthly basis - although OFAC may revoke this authorization at any time

Steven Lofchie Commentary by Steven Lofchie

The U.S. Senate Committee on Agriculture, Nutrition and Forestry (the "Committee") considered the nomination of Dr. Heath P. Tarbert to become the next Chair of the CFTC. Dr. Tarbert is currently the U.S. Treasury Department ("Treasury") Assistant Secretary for International Markets. In testimony before the Committee, Dr. Tarbert stated that, if confirmed as CFTC Chair, one of his obligations would be to ensure that the derivatives markets are "transparent, competitive, financially sound and also free from fraud." He said that an understanding of the derivatives market was insufficient, and

The U.S. Treasury Department ("Treasury") Office of Foreign Assets Control ("OFAC") introduced a List of Foreign Financial Institutions Subject to Correspondent Account or Payable-Through Account Sanctions (the "CAPTA List"). The CAPTA List contains information on foreign financial institutions for which the opening or maintaining of a "correspondent account or a payable-through account" in the United States is barred or is subject to one or more conditions. The CAPTA List replaces the List of Foreign Financial Institutions Subject to Part 561. Separately, OFAC issued amendments to the Iranian