There was lots of big news coming out of the FDIC Board this week − an important Advanced Notice of Proposed Rulemaking on resolution requirements for large banking organizations (announced jointly with the Federal Reserve Board) and the announcement of a 2 basis point increase in deposit insurance assessment rates.  

Also in the news, just yesterday, a three-judge panel of the 5th Circuit Court of Appeals ruled that the funding of the CFPB, as a bureau of the Federal Reserve, is unconstitutional. This is an important decision that is just the latest threat to the structure of the CFPB. We will have more to say on this decision in a forthcoming Client & Friends memo and in next week's Cabinet News and Views. 

Finally, we thank our friends at Conyers in the Cayman Islands for their article on Russia-related financial sanctions. 

For now, we welcome any comments or questions. Just drop me a note here.

Daniel Meade 
Editor, Cabinet News and Views

By Daniel Meade

Partner | Financial Regulation

The Federal Reserve Board and Federal Deposit Insurance Corporation Board issued an Advanced Notice of Proposed Rulemaking titled “Resolution-Related Resource Requirements for Large Banking Organizations.” Separately, but relatedly (if for no other reason than the FRB put it in the same press release as the ANPR), the Office of the Comptroller of the Currency and the FRB approved their respective applications for the merger of MUFG Union Bank into U.S. Bank.

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By Daniel Meade

Partner | Financial Regulation

The FDIC Board finalized its proposal to increase the assessment rates in initial base deposit insurance rates by 2 basis points.

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In this guest article, partners Derek Stenson and Michael O'Connor and associate Sarah Farquhar of Cayman Islands law firm Conyers note that Russia’s invasion of Ukraine has demonstrated again how interconnected the political and financial worlds have become. For those of us in the private equity and finance worlds, it has also given rise to associated challenges posed by the Russia-related financial sanctions that have followed. In the fund finance market, these issues have arisen both for sponsors (who are now faced with issues around freezing the assets of sanctioned investors without being able to remove them) and lenders (some of whom have been faced with credit parties to their facilities who now have sanctioned investors in their LP roster).

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Registration will be closing soon for Cadwalader's annual Finance Forum at the JW Marriott in Charlotte next Thursday, October 27. 

Programming will begin at 1:00 p.m. and continue throughout the afternoon, followed by a networking reception. Click here for a list of current panel topics and to register.