Recent US Bank Legislative and Regulatory Developments: Anything here for non-US banks?
In her column on International Banking, Kathleen A. Scott discusses how some recent legislative, and proposed regulatory, changes could affect non-US banks operating in the United States.
July 19, 2018 at 02:45 PM
2 minute read
Some Highlights of the New Law
• Systemic Risk • Other Regulatory Relief
Proposed Changes to the Volcker Rule
• Proposed SOTUS Changes • Other Proposed Changes Compliance Programs
“Limited trading assets and liabilities”—Banking entities with an average gross sum of less than $1 billion would be presumed to be in compliance with the Volcker Rule and not be required to establish a Volcker Rule compliance program unless otherwise specifically ordered to do so by their primary federal regulator.
“Moderate trading assets and liabilities”—Banking entities with an average gross sum between $1 billion and $10 billion will be required to establish a more simplified compliance program than currently required, but still will need to comply with the current CEO attestation requirement that the banking entity does not, directly or indirectly, guarantee, assume or otherwise insure the obligations or performance of the covered fund or of any covered fund in which the covered fund invests.
“Significant trading assets and liabilities”—Banking entities with an average gross sum of $10 billion or more will be subject to the most detailed compliance program requirements, including written policies and procedures, internal controls, independent testing and audit obligations, and recordkeeping requirements, in addition to the CEO attestation requirement.
NOT FOR REPRINT
© 2024 ALM Global, LLC, All Rights Reserved. Request academic re-use from www.copyright.com. All other uses, submit a request to [email protected]. For more information visit Asset & Logo Licensing.
Trending Stories
- 1The Law Firm Disrupted: For Big Law Names, Shorter is Sweeter
- 2Wine, Dine and Grind (Through the Weekend): Summer Associates Thirst For Experience in 'Real Matters'
- 3The 'Biden Effect' on Senior Attorneys: Should I Stay or Should I Go?
- 4'That's Disappointing': Only 11% of MDL Appointments Went to Attorneys of Color in 2023
- 5'You Are Not Alone': 120 Sex Assault Victims Plan to Sue Sean 'Diddy' Combs
Featured Firms
Law Offices of Gary Martin Hays & Associates, P.C.
(470) 294-1674
Law Offices of Mark E. Salomone
(857) 444-6468
Smith & Hassler
(713) 739-1250