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October 20, 2022

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

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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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. 

Maurine R. Bartlett
Senior Counsel
T. +1 212 504 6218
maurine.bartlett@cwt.com

Brian Foster
Partner
T. +1 212 504 6736
brian.foster@cwt.com

James Frazier
Partner
T. +1 212 504 6963
james.frazier@cwt.com

Mark Howe
Partner
T. +1 202 862 2236
mark.howe@cwt.com

Gregg Jubin
Partner
T. +1 202 862 2485
gregg.jubin@cwt.com

Philip S. Khinda
Partner
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philip.khinda@cwt.com

Ivan Loncar
Partner
T. +1 212 504 6339
ivan.loncar@cwt.com

Peter Y. Malyshev
Partner
T. +1 202 862 2474
peter.malyshev@cwt.com

Daniel Meade
Partner
T. +1 202 862 2294
daniel.meade@cwt.com

Jed Miller
Partner
T. +1 212 504 6821
jed.miller@cwt.com

Michael Newell
Partner
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michael.newell@cwt.com

Alix Prentice
Partner
T.+44 0 20 7170 8710
alix.prentice@cwt.com

Rachel Rodman
Partner
T. +1 202 862 2210
rachel.rodman@cwt.com

Richard M. Schetman
Senior Counsel
T. +1 212 504 6906
richard.schetman@cwt.com

Lary Stromfeld
Partner
T. +1 212 504 6291
lary.stromfeld@cwt.com

Jonathan M. Wainwright
Senior Counsel
T. +1 212 504 6122
jonathan.wainwright@cwt.com

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