23 11, 2022


2022-11-23T12:42:48-05:00November 23rd, 2022|2- Daily Briefing|

OFAC Updates Guidance For Price-Cap Sanction Compliance

Reflecting ongoing negotiations about the level of the oil-price cap, OFAC last night provided updated guidance to banks and insurers about when transactions may violate this latest sanction.  The new guidance identifies “covered services” for financing; this means a commitment for the provision or disbursement of debt, equity, or economic resources related to the maritime transport of Russian oil.  However, and as before, U.S. persons are authorized to provide covered services if the Russian oil is purchased at or below the price cap.

FDIC Signals Tougher GSIB Resolution Reviews

With the FDIC signaling a tough new approach to resolution plan approval, the FRB and FDIC today announced the results of the resolution plans filed by U.S. GSIBs in July, 2021.  All the banking organizations saw their plans approved except for Citigroup, which had noted shortcomings due to data quality and management concerns; the bank now has until January 31, 2023 to submit a revised plan.  FDIC Acting Chairman Gruenberg noted that, going forward, the agencies will conduct more detailed reviews of internal testing results and independent capability assessments.


12 09, 2022


2022-10-13T12:00:09-04:00September 12th, 2022|2- Daily Briefing|

Senate Banking GOP Demand CFPB Recant, Retreat, Redo

All Republican members of the Senate Banking Committee today sent CFPB Director Chopra a scathing letter challenging his legal authority to undertake many recent actions.  The letter specifically cites what it calls the Bureau’s “smear campaign” against banks offering optional overdraft services, calling its February list of the top 20 banks by revenue from overdraft fees an abusive “name-and-shame” tactic.

OFAC Eases Implementation of Oil Price-Cap Sanctions

As anticipated, OFAC late Friday issued initial guidance to banks and insurers on Russian oil price-cap compliance.  Although OFAC plans to follow this guidance with a more comprehensive statement and a “red-flag” advisory, it now makes clear that banks and insurers will not be liable for price-cap violations related to their financing or coverage if the financial company has no independent knowledge of the actual price and reasonably relied on a customer’s attestation.

Fed Study: Credit Profitability Depends on NIM

At a time when credit-card rates reached a quarter-century high, the Fed has released a staff study using new data to conclude that card interest rates are by far the most important source of issuer profitability.  The study decomposes credit-card income into component parts (interchange fees, interest charges, and consumer fees) with interest-rate revenue accounting for eighty percent of card profitability at the largest bank issuers.


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