In This Issue

Business & Corporate

Volcker Rule 2.0: An Overview of Recent Changes and Preview of What’s to Come

As of October 8, 2019, the five agencies responsible for administering the Volcker Rule– the Commodity Futures Trading Commission (CFTC), the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board (FRB), the Office of the Comptroller of the Currency (OCC) and the Securities and Exchange Commission (SEC) – have approved a final rule that revises aspects of the Volcker Rule implementing regulations. Below, we highlight some of the final rule’s most significant changes in the areas of proprietary trading, compliance programs, metrics reporting and covered funds.

Business & Corporate

The Value of a Bank Holding Company

Is the bank holding company structure obsolete or unnecessary? Some might believe that to be the case, but there are a number of reasons why banks should consider maintaining, or even enhancing the use of their holding companies. Most obvious among these reasons to resist eliminating the holding company is the flexibility to grow, diversify, and innovate offered by the bank holding company structure. This is also the same reasoning used to examine the potential benefits of establishing a bank holding company for a bank that does not currently have one.

Business & Corporate

The Transition From LIBOR: A Report at the Halfway Mark

It has been more than two years since the U.K.’s Financial Conduct Authority announced that after the end of 2021, it will not compel any banks to provide quotations upon which LIBOR is based. This announcement gave the markets notice that by that date, all financial products linked to LIBOR—a reported $350 trillion worth—should be migrated to alternative reference rates. This is a mammoth transition project for the financial markets, and some progress has been made—a likely LIBOR successor for U.S. dollars has been identified, and U.S. banks have begun assessing their LIBOR exposures—but an enormous amount of work remains to be done. The transition has many moving parts, each of them presenting potential legal risk.