Partner
Norton Rose Fulbright US LLP
Tim Byrne is a Partner based in New York. He advises major financial institutions on the bank regulatory aspects of financial products and corporate transactions.
Tim advises on a range of other issues from anti-money laundering enforcement matters to bank insolvency issues, capital requirements and outsourcing and vendor management. He is the immediate past chair of the Securities, Capital Markets and Derivatives Subcommittee of the American Bar Association Banking Law Committee.
Recent Articles & Comments
The agreement reflects the assertion of FDIC jurisdiction under the Change in Bank Control Act over large asset management firms that are significant investors in state nonmember banks or companies, including bank holding companies that control state nonmember banks. Investors in such bank holding companies are also subject to Federal Reserve jurisdiction under the same Act and the Bank Holding Company Act.
The Fed generally requires asset management firms to make passivity…
The OCC adopted the guidelines largely as they were proposed in July, including lowering the threshold for application of the guidelines from $250 to $100 billion. It appears that such lowering of the threshold will newly subject approximately 10 institutions to the guidelines, with two or three more approaching the threshold.
The OCC did grant additional time to comply with certain aspects of the guidelines, including the new testing requirement. The OCC also noted that as a…
The action by the FDIC to expand the scope and specificity of resolution plan filing requirements reflects continuing reverberations in the financial services regulatory realm caused by the 2023 bank failures. In Congressional hearings in the aftermath of these failures, officials vowed to tighten regulatory oversight of regional institutions. The FDIC rule and related actions by other agencies all move in that direction. Significantly, imposing an informational filing requirement on all…
The results should help the banks counter arguments that minimum capital levels should be raised even further. Expect the industry to continue pushing for more transparency in the stress-testing process in the future.