#ILC – Page 2 – Federal Financial Analytics

18 05, 2022

DAILY051822

Eliza Allen2023-02-21T14:36:00-05:00May 18th, 2022|2- Daily Briefing|

ILC Restrictions Hit Speedbump

The House Financial Services Committee today attempted to markup H.R. 5912 (Garcia, D-IL), a bill that would subject ILCs and their parent companies to BHC regulation (see FSM Report ILC13). Reflecting concerns about the bill’s grandfather provisions, Rep. Garcia introduced an amendment to the bill that would subject commercial entities looking to acquire an ILC to prior FSOC review.

Barr Highlights Crypto Rules, Equity Ahead of Hearing

Although we will provide clients tomorrow with an in-depth assessment of his confirmation hearing, Michael Barr’s testimony confirms that he will take a different approach to financial regulation than his predecessor, Randy Quarles. His very brief statement emphasizes the need for innovation to come with regulation and for it to advance fairness.

Bill Requiring Cash Acceptance Reported to House

The House Financial Services Committee today reported H.R. 4395 (Payne, D-NJ), a bill that requires all businesses to accept cash payments for transactions under $2000, by a vote of 32-17. The panel added an amendment from Rep. Garcia (D-TX) to clarify that only businesses with a physical location are covered.

Daily051822.pdf…

13 05, 2022

Al051622

Arezou Rafikian2023-02-21T15:16:59-05:00May 13th, 2022|3- This Week|

Mark-Up Mayhem

On Tuesday, the House Financial Services Committee will meet in open, hybrid session to have another go at each other. The increasingly nasty mood was in relative abeyance when Secretary Yellen testified last week (see Client Report FSOC27), but it was on full display later in the day when Republicans launched a full-bore attack against Acting Comptroller Hsu and earlier in the week when what should have been a staid session on the credit-rating agencies became a sparring match between Chairwoman Waters (D-CA) and Rep. Huizenga (R-MI) over who controls the Committee’s agenda. None of these ill feelings has dissipated and all will be in clear view when the panel meets to report several high-profile, controversial measures.

Al051622.pdf…

2 11, 2021

FedFin Assessment: The Near-Term Stablecoin Regulatory Agenda

Arezou Rafikian2023-06-02T13:04:23-04:00November 2nd, 2021|The Vault|

As noted yesterday, the President’s Working Group on Financial Markets (PWG) was joined by the OCC and FDIC yesterday issuing a report calling for prompt Congressional action to regulate stablecoins and, even in its absence, also for fast action by federal regulators and the FSOC. In part because it poses the largest regulatory void, the most worrisome of the risks the report details arises from the role stablecoins may play in the payment system and resulting threats to systemic stability and competition. Issues germane to digital-asset trading (defined to include lending and related activities) are described but largely left to regulators; SEC Chairman Gensler has made it clear (see Client Report INVESTOR19) that he intends to act and the CFTC-chair nominee has done the same.

The full report is available to retainer clients. To find out how you can sign up for the service, click here.

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2 11, 2021

CRYPTO21

Arezou Rafikian2023-06-02T13:03:50-04:00November 2nd, 2021|5- Client Report, Uncategorized|

FedFin Assessment: The Near-Term Stablecoin Regulatory Agenda

As noted yesterday, the President’s Working Group on Financial Markets (PWG) was joined by the OCC and FDIC yesterday issuing a report calling for prompt Congressional action to regulate stablecoins and, even in its absence, also for fast action by federal regulators and the FSOC. In part because it poses the largest regulatory void, the most worrisome of the risks the report details arises from the role stablecoins may play in the payment system and resulting threats to systemic stability and competition. Issues germane to digital-asset trading (defined to include lending and related activities) are described but largely left to regulators; SEC Chairman Gensler has made it clear (see Client Report INVESTOR19) that he intends to act and the CFTC-chair nominee has done the same.

CRYPTO21.pdf…

1 10, 2021

AL100421

Arezou Rafikian2023-07-24T15:29:39-04:00October 1st, 2021|3- This Week|

Back to Work

Although Senate Banking (see Client Report REFORM208) and HFSC’s (see Client Report REFORM209) hearings this week with Secretary Yellen and Chair Powell ostensibly focused on the CARES Act, in reality they covered the waterfront. In between them, HFSC’s Consumer Protection Subcommittee considered risks from fintech and much more (see Client Report MERGER7). This session made clear that a bipartisan consensus is forming around the need to bring fintech inside the regulatory perimeter when not partnering with a bank. At the least, this consensus powers up the banking agencies’ efforts to use their third-party vendor powers to impose consumer-protection and safety-and soundness rules on fintechs linked to banks (see FSM Report VENDOR9). More importantly, they signal initial Congressional alignments that may well lead to substantive legislation in 2022 and, even if they don’t, will surely lead to a new regulatory framework

AL100421.pdf…

29 09, 2021

MERGER7

Arezou Rafikian2023-07-31T16:00:20-04:00September 29th, 2021|5- Client Report|

HFSC Explores Wide Array of Merger, Fintech, ILC Reforms

In a wide-ranging hearing today, HFSC’s Consumer Protection and Financial Institutions Subcommittee showed the extent to which Chairwoman Waters (D-CA) and progressive Democrats are wary of large-bank mergers. Buoyed by witnesses who believe recent large transactions accelerate under-service for communities of color, Democrats suggested new, tougher standards and greater transparency. Republicans countered that regulatory burden exacerbates consolidation. However, both sides of the aisle agreed that fintechs pose an array of risks, with Democrats contending these warrant new ILC standards or even an end to limited-purpose charters. Republicans lambasted the true lender rule reversal, arguing it harms the bank-fintech partnership model they generally supported. For fintechs operating outside of bank partnerships, there was bipartisan agreement that the regulatory playing filed needs to be leveled to reduce arbitrage opportunities.

MERGER7.pdf …