Publication
The New York Department of Financial Services’ cybersecurity regulation
An “acceptable” cybersecurity program has become more objective.
Publication | November 13, 2015
On Oct. 30, 2015, the Federal Reserve Board issued a proposed rule requiring global systemically important banks (GSIBs) to meet new requirements to maintain a “total lossabsorbing capacity” (TLAC) ratio that can be met by a combination of additional regulatory capital and unsecured long-term debt.
This proposal would apply to both U.S. bank holding companies classified as GSIBs and the U.S. operations of non-U.S. banking organizations classified as GSIBs. It is aimed at strengthening the resiliency of the GSIBs on an ongoing basis while providing for a more orderly resolution if a GSIB should fail. Comments are due on or before Feb. 1, 2016. Compliance is proposed to begin Jan. 1, 2019, and be fully phased-in by Jan. 1, 2022.
The proposed TLAC requirement and additional related proposals are quite complex. This month’s column provides a high-level general summary of the proposal. Non-U.S. banks classified as GSIBs with U.S. operations organized under an intermediate holding company (IHC) will be directly affected by this proposal and they will want to analyze whether the U.S. proposal may conflict with current or pending home country laws and regulations.
Read the full article: Total Loss-Absorbing Capacity Proposal comes to the United States
Publication
An “acceptable” cybersecurity program has become more objective.
Publication
The Office of the Comptroller of the Currency issued guidance (Bulletin 2023-37) on December 6, 2023.
Publication
During the ABA’s National Institute on White Collar Crime, the DOJ announced a pilot program that will be created in the next 90 days to provide financial incentives to whistleblowers who assist the DOJ in investigating corporate misconduct.
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