A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk Identification, Assessment, and Response (“Analytic Framework”); and (2) the updated Guidance for Nonbank Financial Company Determinations (“Nonbank Designations Guidance”). The Analytic Framework was published today in […]
Banking Regulatory Agencies
FSOC Issues Proposed Update to Interpretative Guidance on Nonbank Financial Company Designations
A&B Abstract: On April 21, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) issued for public comment (1) a proposed analytic framework setting forth FSOC’s approach to identifying, evaluating, and addressing potential risks to financial stability (“Proposed Analytic Framework”), and (2) proposed revisions to FSOC’s existing 2019 interpretive guidance that FSOC would use […]
Is the DOJ (De Facto) Enforcing the Community Reinvestment Act?
A&B Abstract: Furthering the Justice Department’s Combating Redlining Initiative, the Department of Justice has announced another redlining settlement. But this settlement is different – this one involves a bank that has received top marks by its prudential regulator, the Federal Deposit Insurance Corporation (FDIC), for its compliance with the Community Reinvestment Act (CRA), a statute […]
Modern-Day Redlining Enforcement: A New Baseline
On October 22, 2021, the U.S. Department of Justice (DOJ) announced an aggressive new initiative, in collaboration with U.S. Attorneys’ Offices throughout the country, to combat the practice of redlining. Three days prior, the Consumer Financial Protection Bureau (CFPB) was said to be hiring up to 30 new enforcement attorneys to focus on redlining and […]
Alston & Bird Welcomes Brendan Clegg
Brendan Clegg joined Alston & Bird in March 2021 as counsel in the Financial Services & Products Group in Washington, D.C. He focuses his practice on state and federal bank regulatory issues and advises bank and non-bank clients regarding Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance. He also represents bank […]