6 03, 2024


2024-03-06T16:51:12-05:00March 6th, 2024|2- Daily Briefing|

Bowman Renews Tailoring Defense

In dinner remarks last night, FRB Gov. Bowman argued that tailoring is a “grounding principle” of bank regulation ignored in the pending capital rules and final climate guidance (see FSM Report CLIMATE17), standards she also said are intended to allocate capital, not ensure effective supervision.

GAO Reviews Fed, FDIC Supervisory Practices

The GAO today issued a report examining the Fed and FDIC’s communication and escalation of supervisory concerns towards SVB and Signature prior to their collapse, finding that a lack of clarity and specificity in the Fed’s enforcement procedures contributed to delays in escalation towards SVB.

Scope 3 Removed From Final SEC Climate Disclosure Rule

The SEC today voted 3-2 to finalize its 2022 climate-risk disclosure proposal, opting to remove its controversial Scope 3 provisions.


13 12, 2023


2023-12-13T16:50:12-05:00December 13th, 2023|2- Daily Briefing|

HFSC Oversight Subcomm Revisits Iran Sanctions

Today’s HFSC Oversight Subcommittee hearing focused on the Biden Administration’s recent efforts to limit terrorist funding from Iran.  Chairman Huizenga (R-MI) questioned the need for the November 14th renewal of a waiver that allows Iraq to pay Iran for electricity, calling for increased pressure on Iran following Hamas’s October 7th attack.

SEC Sets Out Treasury Central-Clearing Construct

As anticipated, the SEC this morning voted 4-1 to mandate central clearing for Treasury securities used in many repo and reverse-repo transactions, modifying the proposal in key respects still unsatisfactory to Commissioner Peirce.  The rule addresses continuing concerns about Treasury-market fragility, in part by reducing the number of highly-leveraged hedge-fund transactions.

GAO Reaches Equivocal Verdict on Digital-Asset Crypto Evasion Risk

Addressing Congressional concerns such as those in the Warren-Marshall crypto-compliance bill, the GAO today issued a report finding that digital assets pose risk to U.S. sanction implementation and enforcement despite mitigating factors that may reduce certain risks.

Brown Presses Bank CEOs on Servicemember Rights

A week after the GSIB CEOs came before the Senate Banking Committee (see Client Report GSIB23), Banking Committee Chair Brown (D-OH) today sent a letter to the CEOs of the four largest consumer banks encouraging them to ensure that active-duty servicemembers obtain all the financial benefits to which they are entitled.


21 03, 2022


2023-04-03T13:15:47-04:00March 21st, 2022|2- Daily Briefing|

FSB Cites Growing FinTech/BigTech Concerns, Policy Solutions Await

The FSB today published its latest assessment of fintech, now adding bigtech to the picture and elaborating on the array of policy concerns it and BIS have previously sketched out.  We will shortly provide clients with an in-depth analysis of a report which concludes that the pandemic has significantly accelerated digital transformation.  This improves financial inclusion, but raises growing risk of structural change by way of dominant players outside the regulatory perimeter.

SEC Sets Out Sweeping U.S. Climate-Risk Disclosure Construct

On unsurprising party lines (3-1), the SEC today released proposed climate-risk disclosures for public registrants.  Although Congressional Democrats pressed for express materiality standards, the proposal relies on current interpretations of what must be disclosed.  Although Congressional Republicans derided the proposal as far outside the Commission’s mandate, it would require not only Scope 1 and 2 disclosures, but also an initial construct designed to lead gradually, but indisputably, to Scope 3 disclosures from larger companies.


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