#DSIB

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9 11, 2022

DAILY110922

2022-11-09T16:59:00-05:00November 9th, 2022|2- Daily Briefing|

FIO, HHS Plan Longer Ponder on Federal Cyberinsurance

The Federal Insurance Office and the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency today extended the comment deadline for comments on whether a federal insurance response is warranted for catastrophic cyber risk.  The earlier notice asked what type of catastrophic attacks on U.S. critical infrastructure are most likely, how best to measure their effect, the current catastrophic insurance landscape, and how any federal insurance should be structured.

FDIC Board Stands By DSIB Resolution Reform

At today’s FDIC Systemic Resolution Advisory Committee session, Acting Chairman Martin Gruenberg defended the release of proposed DSIB resolution standards as guidelines, not rules.  Director Chopra reiterated concerns he expressed at a recent FDIC board meeting (see Client Report DEPOSITINSURANCE115), pressing for a structural rewrite of both DSIB and GSIB resolution standards.  Acting Comptroller Hsu focused largely on supervisory build-out, noting the need for more creative, forward-looking assessments of resolution plans.  Mr. Hsu also wants regulatory statements to ensure that investors understand that TLAC is a buffer of capital-at-risk in the event of extreme stress.

Daily110922.pdf

24 10, 2022

DAILY102422

2022-10-24T16:48:00-04:00October 24th, 2022|2- Daily Briefing|

Deadline Set for D-SIB Resolution Comment

The Federal Register today included the Fed/FDIC D-SIB resolution ANPR, as announced last week (see Client Report DEPOSITINSURANCE115).  As analyzed in our in-depth report (see FSM Report RESOLVE48), the agencies seek comment on whether requiring D-SIBs to have TLAC standards akin to those mandated for G-SIBs would enhance resolvability, as well as seeking input on extending clearing holding company requirements to D-SIBs, disclosure standards in the event of a resolution, and explicit severability plans.

FHFA Advances Equitable Finance With New Fees, Credit Score Options

Building on its 2022 scorecards and January’s up-front fee price hikes, FHFA today announced it will eliminate upfront fees – aka, delivery fees or loan-level price adjustments (LLPAs) – for certain borrowers and affordable mortgage products.  The Agency will also implement targeted increases to the upfront fees for most cash-out refinance loans.  Upfront fees will be eliminated for: first time homebuyers at or below 100% of area median income (AMI) and below 120% AMI in high-cost areas; HomeReady and Home Possible loans, which are Fannie and Freddie’s flagship affordable housing products; HFA Advantage and HFA Preferred loans; and single-family loans supporting the Duty to Serve program.

Daily102422.pdf

21 10, 2022

FedFin on: DSIB-Resolution Requirements

2022-10-21T15:51:53-04:00October 21st, 2022|The Vault|

The FRB and FDIC have moved beyond the resolution-planning requirements mandated in the Dodd-Frank Act then implemented over the years to what could be a new resolution regime for banking organizations considered category II or III companies under the inter-agency tailoring rules.  Initially described as guidance when the agencies first announced this initiative, it appears likely that final standards will be more binding, which would almost certainly need to be the case under administrative procedures if the agencies decide not only to revise resolution planning on a sector or bank-by-bank case.  This would be particularly likely if ….

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21 10, 2022

RESOLVE48

2022-10-21T14:12:50-04:00October 21st, 2022|1- Financial Services Management|

DSIB-Resolution Requirements

The FRB and FDIC have moved beyond the resolution-planning requirements mandated in the Dodd-Frank Act then implemented over the years to what could be a new resolution regime for banking organizations considered category II or III companies under the inter-agency tailoring rules. Initially described as guidance when the agencies first announced this initiative, it appears likely that final standards will be more binding, which would almost certainly need to be the case under administrative procedures if the agencies decide not only to revise resolution planning on a sector or bank-by-bank case. This would be particularly likely if the agencies decide to include them in total loss-absorbency capacity (TLAC) standard for covered banking organizations akin to those now governing GSIBs.

RESOLVE48.pdf

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