Senior Associate
Norton Rose Fulbright US LLP
Sebastian Souchet focuses his practice on representing US and non-US banks, broker-dealers and “buy-side” market participants on bank regulatory matters and regulatory, transactional and compliance issues related to securities and derivatives.
More specifically, Sebastian has experience advising US and non-US banks, bank holding companies, and other financial market participants on various bank regulatory issues including capital requirements, licensing/chartering requirements, control issues, affiliate and insider transactions, and the Volcker Rule.
Sebastian also has experience representing US and non-US banks and broker-dealers on various requirements arising under the US securities laws and the Commodity Exchange Act, including requirements relating to trading, supervision, recordkeeping, reporting, capital, margin and communications/marketing, as well as SEC and CFTC regulatory requirements arising under Title VII of the Dodd-Frank Act.
Sebastian also advises clients on complex financial transactions and has experience drafting and negotiating securities and derivatives trading documentation, including prime brokerage agreements, ISDA Master Agreements and various other industry-standard and bespoke trading and financing contracts.
Recent Articles & Comments
Consider the following initial takeaways:
Comparison to the 2018 FRB and OCC Proposal. The FRB and OCC's 2018 proposal regarding eSLR reform served, at least to some extent, as precedent for the US prudential regulators' current eSLR reform proposal. Both proposals (i) seek to better align the eSLR with risk-based capital requirements (so that risk-based capital requirements serve as the binding regulations rather than the leverage capital requirements); and (ii) tie a G-SIB's eSLR…In their comment letter, SIFMA/ISDA advocate for "asymmetric averaging," which would "allow[] for more timely recognition of reduced risks and give[] large banking organizations time to managed increased risks." However, neither the FRB proposal's approach to averaging, nor the SIFMA/ISDA letter's asymmetric averaging approach, appears to distinguish between year-over-year volatility driven by changes in stress test scenario design and volatility driven by material…
The bipartisan letter is particularly timely given: (i) recent remarks from Vice Chair Bowman identifying, among other things, leverage capital requirements as an area requiring review and recalibration (); (ii) Acting OCC Comptroller Hood's June 2025 stating that the OCC is "examining adjustments to the [SLR] to ensure it functions as a true backstop—not a primary constraint that limits lending unnecessarily"; and (iii) that the FDIC a draft rule to the Office of…
A few points on Ms. Bowman's first remarks as Vice Chair for Supervision:
Tailoring and International Comparability. Tailoring is almost certain to be a core feature of Ms. Bowman's prudential regulatory and supervisory policy approach. Vice Chair Bowman has also the need for policymakers to consider "international comparability and competitive disadvantages" regarding implementation of international standards, such as the Basel III framework. While Vice…