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Volcker Rule Impact When Crossing $10 Billion

January 14, 2019

Authors

Robert Klingler

Volcker Rule Impact When Crossing $10 Billion

January 14, 2019

by: Robert Klingler

Under the Economic Growth, Regulatory Reform and Consumer Protection Act, depository institutions and their holding companies with less than $10 billion in assets are excluded from the prohibitions of the Volcker Rule. Accordingly, institutions under $10 billion may, so long as consistent with general safety and soundness concerns, engage once again in proprietary trading and in making investments in covered funds.

On December 21, 2018, the federal regulatory agencies proposed

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Did Congress Release Nearly All Banks from the Volcker Rule?

January 9, 2019

Authors

Robert Klingler

Did Congress Release Nearly All Banks from the Volcker Rule?

January 9, 2019

by: Robert Klingler

Yes.  

The Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA) provided significant regulatory relief for community banks, including broad relief from the Volcker Rule’s prohibition on proprietary trading and investments in covered funds. As previously discussed, Section 203 of EGRRCPA provided an exemption from the Volcker Rule for institutions that are less than $10 billion and whose total trading assets and liabilities are not more than 5% of total consolidated assets. The exemption provides complete relief from the Volcker Rule by exempting such depository institutions from the definition of “banking entity” for purposes of the Volcker Rule.

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A Holiday Buffet of Banking News

December 28, 2018

Authors

Robert Klingler

A Holiday Buffet of Banking News

December 28, 2018

by: Robert Klingler

On December 27th, Jonathan and I returned to the studio to record the latest podcast for The Bank Account. We haven’t discussed New Year’s Resolutions, but we’ll try to return to a little more normalcy in 2019!

For those that have missing our voices, (a) please seek help… that’s not normal and (b) we were also recently guests on the ABA Banking Journal Podcast.

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Regulators Propose Community Bank Leverage Ratio Framework

November 28, 2018

Authors

Robert Klingler

Regulators Propose Community Bank Leverage Ratio Framework

November 28, 2018

by: Robert Klingler

On November 21, 2018, the Federal Reserve, Office of Comptroller of the Currency and the FDIC jointly published a notice of proposed rulemaking (the “NPR”) to provide an alternative capital system for qualifying banking organizations.  Specifically, the regulators have proposed a new, alternative, simplified capital regime for qualifying institutions that will deem an institution to be well-capitalized so long as it maintains a leverage ratio of at least 9% and adequately capitalized so long as it maintains a leverage ratio of at least 7.5%.

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Acronym Soup: A Discussion of Regulatory Reform

October 2, 2018

Authors

Robert Klingler

Acronym Soup: A Discussion of Regulatory Reform

October 2, 2018

by: Robert Klingler

On September 28th, Jonathan and I recorded a brief podcast on the impact of regulatory reform on community banks in 2018.  Before turning to substance, I first congratulated Jonathan on his ability to combine two of our shared passions: college football and mergers & acquisitions.  Jonathan’s post on a Football Fan’s

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Two Key EGRRCPA Provisions Now Effective

September 10, 2018

Authors

Robert Klingler

Two Key EGRRCPA Provisions Now Effective

September 10, 2018

by: Robert Klingler

As of the end of August 2018, two key provisions of The Economic Growth, Regulatory Relief, and Consumer Protection Act (aka the Crapo bill, S.2155, or increasingly, EGRRCPA) have become effective: the increase in the small bank holding company policy statement threshold and the increase in the expanded examination cycle threshold.  Before looking at those provisions, I have to acknowledge the fabulous Wall Street Journal story by Ryan Tracy, “Can You Say EGRRCPA? Tongue-Twister Banking Law Confuses Washington.”  Personally, I’m now leaning towards “egg-rah-sip-uh.”

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