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
FRB Governor Bowman raises several issues that are critical to the ongoing policy discussion regarding the proper calibration of stress testing as a macroprudential regulatory and supervisory tool used to address systemic financial risks and related bank capital impacts. However, query to what extent addressing the concern of "excessive year-over-year volatility, which flows through to calculation of stress capital buffers," would run counter to what former FRB Governor Daniel Tarullo has…
Taken together, the statements by Senator Scott and the Democratic congressmembers are further evidence of how the federal banking regulators eventual re-proposal of the Basel III endgame rules is not only a product of banks and industry trade groups raising numerous legitimate concerns over the impact of the original July 2023 proposal, but also of bipartisan support in Congress for such re-proposal.
In his speech outlining recommendations for a re-proposal of the Basel III endgame, Mr. Barr stated his intention to recommend to the FRB that Category IV firms not be subject to the Basel III endgame changes (subject to potential application of the revised market risk framework where a Category IV firm has significant trading operations). This is interesting given that at the time of Silicon Valley Bank's failure, Silicon Valley Bank Financial Group (the bank holding company the principal…
Mr. Barr's speech effectively confirms what has been telegraphed over the past year by the federal banking regulators—there will be a material re-proposal of the so-called Basel III endgame.
A few additional highlights from Mr. Barr's speech (and the Q&A session that followed):
Overall Capital Impact. Mr. Barr states that the re-proposals will increase aggregate CET1 capital requirements for the G-SIBs by 9%, and that large non-G-SIB firms would ultimately see an…