US Regulatory Research
FinCEN Issues Guidance Regarding Virtual Currencies
On 9 May, the Financial Crimes Enforcement Network (“FinCEN”) issued guidance entitled “Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies (“CVC”).” A CVC generally is a virtual currency that can be substituted for a legal currency (e.g., Bitcoin). As noted by the guidance, it was issued “in response to questions raised by financial institutions law enforcement, and regulators concerning the regulatory treatment of multiple variations of businesses dealing in CVCs.” FinCEN also issued guidance entitled “Advisory on Illicit Activity Involving Convertible Virtual Currency,” “which is intended to assist financial institutions in identifying and reporting suspicious activity related to criminal exploitation of CVCs for money laundering, sanctions evasion, and other illicit financing activities.” The guidance does not represent new regulatory expectations and instead “consolidates current FinCEN regulations, guidance and administrative rulings that relate to money transmission involving virtual currency.”
Twenty-Five Congressmen Send Letter to SEC Chairman Clayton Regarding CECL Standard
On 6 May, 25 members of the U.S House of Representatives sent a letter to Securities and Exchange Commission (“SEC”) Chairman Jay Clayton expressing “concern that the Current Expected Credit Loss (“CECL”) accounting standard (“CECL”) will adversely impact the cost and availability of credit once fully implemented.” The letter describes several potential detrimental effects the new standard will have, including raising “the costs of essential products such as the 30-year mortgage and small business loans while failing to adequately protect banks from the volatility of economic downturns.”
Senate Banking Committee Holds Hearing on Privacy Rights and Data Collection
On 7 May, the U.S. Senate Committee on Banking, Housing, and Urban Affairs (“Senate Banking Committee”) held a hearing entitled “Privacy Rights and Data Collection in a Digital Economy.” Testifying at the hearing were: Peter Chase, Senior Fellow, The German Marshall Fund of the United States; Jay Cline, Privacy and Consumer Protection Leader, Principal, PwC US; and Maciej Ceglowski, Founder, Pinboard. Committee Chairman Crapo (R-ID) noted that both federal regulators and private companies alike are collecting considerable data on individuals and that “[c]onsumers deserve to know what type of information is being collected about them, what that information is being used for and how it is being shared.” Providing perspective on the EU’s General Data Protection Regulation (“GDPR”), Chase stated, “Although long, GDPR is simple. It lays out six principles that govern the protection of personal data in the European Union, and derives from those a number of rights for individuals and obligations for those who have the data.” Cline emphasized that with respect to GDPR, “some privacy rights appear more popular with individuals than others,” and “a formalized data governance program is critical for data privacy’s success and forward progress.” Ceglowski expressed concern in his industry that “[w]e have an amazing new technology with real potential, but we’re not being honest about the risks in incapacity to store wasteful and harmful by product for periods of time.”
House Financial Services Committee Markup
On 8 May, the U.S. House Committee on Financial Services (“House Financial Services Committee”) held a markup, in which the committee agreed to:
o a resolution establishing the Task Force on Financial Technology in the House Committee on Financial Services, and
o a resolution to establish the Task Force on Artificial Intelligence in the House Committee on Financial Services.
The Committee also advanced the following bills favorably:
o H.R. 2409, The Expanding Access to Capital for Rural Job Creators Act, which would amend the Securities Exchange Act of 1934 to expand access to capital for rural-area small businesses, among other things;
o H.R. 2514, The Coordinating Oversight, Upgrading and Innovating Technology, and Examiner Reform Act of 2019, as amended twice, which would amend the Bank Secrecy Act to make changes to the Treasury Department and FinCEN, including the creation of (i) a Treasury Civil Liberties and Privacy Officer in each financial regulator and (ii) an interagency Civil Liberties and Privacy Council through which collaboration on Bank Secrecy Act/Anti-Money Laundering issues can occur;
o H.R. 2534, The Insider Trading Prohibition Act of 2019, as amended, which would codify the definition of “illegal insider trading” under the securities laws to create a “consistent standard for both courts and market participants to follow.”
Republican Senate Committee Chairman Send Letter to Heads of Banking Regulators
On 8 May, U.S. Senate Banking Committee Chairman Crapo and U.S. Senate Agriculture Committee Chairman Pat Roberts (R-KS) sent a letter to the heads of the Federal Reserve (“Fed”), Office of the Comptroller of the Currency, and Federal Deposit Insurance Corporation (“FDIC”). In the letter, the senators expressed specific concerns about those agencies’ notice of proposed rulemaking on the “Standardized Approach for Calculating the Exposure Amount of Derivates Contracts,” particularly the aspects of the proposal that would result in “significantly higher capital charges [being] assigned to unmargined derivatives.” Separately, the senators also expressed “concerns about different regulators’ margin requirements for interaffiliate swaps,” specifically the differences between the banking agencies and the Commodity Futures Trading Commission (“CFTC”).
House Financial Services Committee Chairwoman Waters Sends Letter to Banking Regulators
On 8 May, House Financial Services Committee Chairwoman Maxine Waters (D-CA) sent a letter to the heads of the Fed and FDIC requesting that they postpone any final decisions on the SunTrust and BB&T merger application until after her committee has conducted “a full and thorough review of the proposed merger.”
On 8 May, the U.S. Senate confirmed the nominations of the following new members of the board of directors of the Export-Import Bank of the United States: Kimberly Reed (as President and Chairman of the Board of Directors), Spencer Bachus III, and Judith Pryor.
SEC & Securities
SEC OCIE Director Delivers Remarks on Retail Investor Protection
On 6 May, the SEC published 29 April remarks of the Director of the SEC’s Office of Compliance Inspections and Examinations (“OCIE”), Peter Driscoll, which were delivered at the National Regulatory Services Spring 2019 Compliance Conference in Orlando, Florida. In his remarks, Driscoll outlined OCIE efforts to protect retail investors through its examinations program and through a new pilot roundtable series with chief compliance officers. Specifically, Driscoll provided an overview of OCIE’s examinations processes and priorities regarding: (i) fees, expenses, and related disclosures; (ii) the safeguarding of client assets; (iii) undisclosed conflicts of interests; (iv) firms borrowing from clients; and (v) the protection of seniors. Driscoll also shared OCIE’s observations concerning investment advisers’ disclosure of certain conflicts of interest, specifically where the adviser: (i) recommends certain investments to its clients where it also has interest in the investment; (ii) must allocate investment opportunities (a) among multiple clients with the same or similar investment strategies or (b) between the adviser and its clients; (iii) recommends the use of affiliated broker-dealers or service providers; and (iv) “has an incentive to recommend certain share classes over others based on the amount of compensation they will receive when their recommendations are executed.” With regard to the latter, Driscoll noted that despite recent SEC enforcement actions concerning 12b-1 fee disclosures, “OCIE does not intend to rest on its laurels in this area and with disclosures of conflicts in general – it is continuing to examine for this issue – and continuing to observe deficiencies.”
SEC Chairman Clayton Testifies Before Senate Appropriations Committee’s Subcommittee on Financial Services and General Government
On 8 May, SEC Chairman Clayton testified before the U.S. Senate Committee on Appropriations’ (“Senate Appropriations Committee”) Subcommittee on Financial Services and General Government. Clayton stated that the SEC is requesting $1.746 billion for its 2020 fiscal year budget, which represents a 4.2 percent increase over fiscal year 2019 enacted levels. He noted that this funding level would “enable the SEC to fill approximately one-third of the approximately 400 positions lost due to the hiring freeze” and includes additional funding for information technology and cybersecurity upgrades. With respect to cybersecurity, Clayton stated: “it is incumbent upon [the SEC] to continue to devote substantial resources and attention to cybersecurity, including the protection of personally identifiable information [(“PII”)].” In this regard, the SEC is “closely scrutinizing how [it] can reduce any potential exposure of PII contained in SEC systems, including EDGAR.” Clayton explained how the requested funding would be used to execute initiatives identified in the SEC’s 2018-2022 Strategic Plan, particularly in pursuit of goals to: (i) focus on the interests of long-term Main Street investors, (ii) “be innovative and responsive,” and (iii) “elevat[e] the agency’s performance through technology, data analytics and human capital.” Specifically, Clayton outlined how Proposed Regulation Best Interest would advance the SEC’s goal to protect the interests of Main Street investors. He also highlighted several initiatives designed to facilitate capital formation, including efforts of the SEC’s Division of Corporation Finance to: (i) review voluntary draft registration statement submissions for initial public offerings; (ii) amend the definition of “accelerated filer” to “reduce the number of smaller companies that are required to provide the auditor attestation report” in accordance with Section 404(b) of the Sarbanes-Oxley Act of 2002; and (iii) improve the proxy process, in coordination with the SEC’s Division of Investment Management. With respect to enforcement, Clayton highlighted that the SEC returned $1.07 billion and $794 million to harmed investors in fiscal years 2017 and 2018 and returned $125 million in connection with its mutual fund share class initiative. Clayton also described SEC efforts to recognize and respond to market developments and trends, modernize its disclosure framework, and conduct retrospective reviews of SEC rules.
SEC Approves Proposal to Amend Accelerated and Large Accelerated Filer Definitions
On 9 May, the SEC approved proposed amendments to the “accelerated filer” and “large accelerated filer” definitions to more appropriately tailor the types of companies that fall within the definitions “while maintaining effective investor protections.” The SEC expects that the proposal would reduce costs for certain lower-revenue companies by exempting smaller reporting companies with less than $100 million in revenues from requirements established by the Sarbanes-Oxley Act of 2002 to obtain an attestation of their internal control over financial reporting (“ICFR”) from an independent outside auditor.
o Chairman Clayton issued a statement regarding the proposal, explaining that the amendments are “aimed at a subset of smaller companies where the additional requirement of an ICFR auditor attestation may not be an efficient way of benefiting and protecting investors.” He clarified: “I note that we are not considering any change to the Sarbanes-Oxley’s requirements that apply to our smaller reporting companies with respect to independent audit committees, CEO and CFO certifications of financial reporting, or the requirement that such companies continue to establish, maintain, and assess the effectiveness of their internal control over financial reporting.”
o SEC Commissioner Robert Jackson issued a statement regarding the proposed amendments, providing the results of an analysis conducted by his office “that shows, for two reasons, why th[e] proposal has little basis in evidence from today’s marketplace.” Jackson’s analysis identified two key issues: (i) the proposal’s “analysis of the costs of Section 404(b) relies heavily on a study using data from 2004 to show that companies with a public float under $75 million -- the level under which auditor attestation is not required -- seemed to ‘bunch’ under that threshold,” a finding which Jackson noted he could not replicate using 2017 data; and (ii) the “proposal makes no serious attempt to evaluate the benefits of attestation,” which Jackson attempted to remedy by conducting a study of “how investors react to news of an internal control failure in two groups of companies: those that would receive a rollback of 404(b) under today’s proposals and those who would not.” He explained that the results of his latter study suggest that “investors care most about the information produced by the attestation requirement at exactly the firms that today’s proposal would exempt from Section 404(b).”
SEC Commissioner Peirce Delivers Remarks Entitled “How We Howey”
On 9 May, SEC Commissioner Hester Peirce delivered remarks by video at the Securities Enforcement Forum in East Palo Alto, California. Peirce’s remarks were entitled “How We Howey,” in reference to the U.S. Supreme Court’s Howey decision, which provided the framework for determining when digital assets may be considered a regulated security. In her remarks, Peirce addressed concerns regarding recent SEC developments related to digital assets, specifically regarding the SEC staff’s recently published Framework for “Investment Contract” Analysis of Digital Assets and the first digital token no-action letter. Peirce expressed concern that “non-lawyers and lawyers not steeped in securities law and its attendant lore will not know what to make” of the SEC’s framework and remarked that the SEC staff’s no-action letter “may in fact have the effect of broadening the perceived reach of our securities laws,” given that “If [the] tokens were securities, it would be hard to distinguish them from any medium of stored value.” Peirce also emphasized that the SEC’s silence on “core questions” related to the public issuance of digital securities “may ultimately be deadly” because an “issuer can conduct a private securities offering with no SEC involvement.”
SEC Proposes Actions to Improve Cross-Border Application of Security-Based Swap Requirements
On 10 May, the SEC proposed a package of rule amendments and interpretive guidance to improve the framework for regulating cross-border security-based swaps (“SBS”) transactions and market participants. The proposal addresses: (i) the use of transactions that have been “arranged, negotiated, or executed” by personnel located in the United States as a trigger for regulating SBSs; (ii) the requirement that non-US resident SBS dealers and major SBS participants certify and provide an opinion of counsel that the Commission can access their books and records and conduct onsite inspections and exams; (iii) the cross-border application of statutory disqualification provisions; and (iv) the questionnaires or employment applications that SBS dealers and major SBS participants must maintain with regard to their foreign associated persons.
CFTC & Derivatives
CFTC Chairman Giancarlo Testifies Before Senate Appropriations Committee’s Subcommittee on Financial Services and General Government
On 8 May, CFTC Chairman J. Christopher Giancarlo testified before the Senate Appropriations Committee’s Subcommittee on Financial Services and General Government. During his testimony, Giancarlo recalled the three-part agenda he established in 2017, which involved: “completing unfinished business of the past, improving current operations, and preparing for the future, what [he] call[s] becoming a 21st Century digital regulator.” He explained that the CFTC’s fiscal year 2020 budget request, which was designed to support this agenda, includes a $284 million request for annual operational funding that represents “the level of funding necessary to fulfill the CFTC’s statutory mission” and a $31 million request to support the relocation of three regional offices. Giancarlo addressed numerous topics related to the CFTC’s budget request, including: (i) the CFTC’s role as a “21st century regulator”; (ii) economic modelling and econometric capabilities; (iii) cybersecurity; (iv) agency reform and the “Keep It Simple Stupid” initiative; (v) Dodd-Frank rulemaking; (vi) swap execution facility reforms; (vii) increased examinations of clearinghouses; (viii) effective international engagement; (ix) enforcement; and (ix) agricultural commodity futures. On the subject of cybersecurity, Giancarlo highlighted that the CFTC “seeks new IT security resources to continue progress towards achieving compliance with Federal Information Security Management Act (“FISMA”) and related Office of Management and Budget (“OMB”) security mandates and ensuring the protection of sensitive market participant data.” He also emphasized the impact of funding to support the CFTC’s oversight of clearinghouses, noting that the CFTC (i) “anticipates new applications for [derivatives clearing organization (“DCO”)] registration resulting from the explosion of interest in crypto currencies” and (ii) “expects to grow our stress testing program to help ensure that the clearing eco-system continues to be resilient to absorb both market and systemic shocks.”
CFTC’ s Division of Enforcement Issues First Enforcement Manual
On 8 May, the CFTC published its first enforcement manual, which establishes “certain general policies and procedures that guide the work of [Division of Enforcement (“CFTC Enforcement”)] staff in detecting, investigating, and prosecuting violations of the Commodity Exchange Act (“CEA”) and the CFTC Regulations.” The manual includes eleven sections describing how CFTC Enforcement is organized, how it processes and detects leads, how it conducts investigations and litigates cases, how its self-reporting, cooperation and Whistleblower programs work, and how it evaluates issues of privileges and confidentiality. The manual also describes CFTC Enforcement’s “Wells process” (regarding the notice sent by the CFTC at the conclusion of an investigation) and how it works in parallel with other civil and criminal agencies.
o On 8 May, the Director of CFTC Enforcement, James McDonald, delivered remarks at the Future Industry Association’s Law & Compliance Division’s annual conference, during which he announced the publication of the CFTC’s enforcement manual. McDonald noted that the manual’s publication “is part of a broader agency effort to advance policy-neutral reforms designed to make us better regulators.” He added that CFTC Enforcement expects the manual will be a “living document,” which will be updated as CFTC Enforcement develops new policies and procedures and refines its thinking about existing policies and procedures.
CFTC Chairman Giancarlo Delivers Speech on Derivatives Clearing
On 10 May, CFTC Chairman Giancarlo delivered a speech on derivatives clearing and clearinghouse resiliency, recovery, and resolution. Giancarlo began his speech by highlighting that the derivatives market focuses on risk mitigation as opposed to risk elimination and that the primary methods of risk mitigation in derivatives markets is central counterparty (“CCP”) clearing. He then discussed the historical evolution and current practices of derivatives clearing and examined the CFTC’s approach to clearinghouse resiliency, recovery, and resolution, including the different functions of the CFTC and how each function oversees or enforces the derivatives market. He also discussed certain international standards for clearinghouse recovery and resolution. Looking forward, Giancarlo stated that the CFTC will: (i) “enhance [its] qualitative DCO examination capabilities while keenly expanding [its] quantitative analysis competence and proficiency”; (ii) “expand the scope of [its] risk analysis to cover both cleared and uncleared swaps”; and (iii) “map the inter-connectedness of regulated derivatives markets to the broader financial system and study risk transmission throughout.”
Fed Publishes Second Financial Stability Report
On 6 May, the Fed published its second Financial Stabliity Report (“FSR”), which “summarizes the [Fed’s] framework for assessing the resilience of the U.S. financial system and presents the Board’s current assessment.” Key conclusions set forth in the FSR are:
o “Valuation pressures remain elevated in a number of markets, with investors continuing to exhibit high appetite for risk, although some pressures have eased a bit since the November FSR.”
o “Borrowing by businesses is historically high relative to gross domestic product (“GDP”), with the most rapid increases in debt concentrated among the riskiest firms amid signs of deterioriating credit standards. In contrast, household borrowing remains at a modest level relative to incomes, and the debt owed by borrowers with credit scores below prime has remained flat.”
o “The largest U.S. banks remain strongly capitalized, and the leverage of broker-dealers is below pre-crisis levels. Insurance companies appears to be in relativelyty strong financial positions. Hedge fund leverage appears to have declined over the past six months.”
o “Funding risks in the financial system are low. Estimates of the outstanding total amount of financial system liabilities that are most vulnerable to runs, including those issued by nonbanks, remain modest relative to levels leading up to the financial crisis. Short-term wholesale funding continues to be low compared with other liabilities, and the ratio of high-quality liquid assets to total assets remains high at large banks.”
Fed Vice Chair for Supervision Quarles Delivers Remarks at Yale School of Management
On 7 May, Fed Vice Chair for Supervision Randal Quarles delivered remarks at the Yale School of Management regarding a number of financial and monetary topics. These topics include: (i) the FSR that was published on 6 May 2019, which Quarles stated would be more targeted than the other existing financial stability reports and would publicly disclose how the Fed is thinking about addressing financial stability issues; (ii) risks and issues relating to leveraged credit and collateralized loan obligations; (iii) the criteria used by the Fed to determine when to utilize the counter-cyclical buffer; (iv) the Fed’s approach to regulation and supervision, as well as the Fed’s process for determining whether certain supervisory guidance documents are considered “rules” for purposes of the Congressional Review Act; (v) the Fed’s ongoing review of its monetary policy strategy, tools, and communication practices; (vi) mechanism that could be put in place to monitor and protect the market from risk relating to never-before-seen financial products or instruments; and (vii) designation of non-bank insitutions as systemically important financial institutions by the Financial Stability Oversight Council.
Fed Governor Brainard Delivers Speech Entitled “How Does Monetary Policy Affect Your Community”
On 8 May, Fed Governor Lael Brainard delivered a speech at the Federal Reserve Bank of Richmond’s Richmond Community Listening Session entitled “’Fed Listens’ in Richmond: How Does Monetary Policy Affect Your Community?” Governor Brainard discussed the Fed’s two goals of achieving maximum employment and price stability and explained how the Fed is reviewing its monetary policies in light of the way the economy is changing, which he refers to as the "new normal." She explains this new normal includes low interest rates and low sensitivity of inflation to economic activity and employment. Brainard believes these factors could be addressed by: (i) holding interest rates lower after a recession is over or not raising interest rates until a particular unemployment rate has been achieved; (ii) average inflation targeting, where the Fed would aim to ”achieve its inflation objective on average over a longer period of time -- perhaps over the business cycle”; or (iii) targeting the yield on specific securities. She concluded her speech by indicating that the Fed will hold a national-level conference in Chicago in June and looks forward to receiving feedback regarding how to address the new normal.
Fed Requests Comments on Proposed Amendments to the Operating Hours for the Fed’s NSS and Fedwire Fund Service
On 9 May, the Fed requested comments on (i) potential amendments to the Fed’s National Settlement Service (“NSS”) and Fedwire Fund Service to support enhancements to the same-day automated clearinghouse (“ACH”) service and (ii) corresponding amendments to the Federal Reserve Policy on Payment System Risk related to a new posting time for transactions and an increased daylight overdraft fee. These amendments include, among others: (i) “extending the closing of NSS by one hour to 6:30 p.m. ET”; (ii) “extending the cutoff time for Reserve Bank accountholders to initiate transfers on behalf of third parties via the Fedwire Funds Service . . . by 45 minutes to 6:45 p.m. ET”; and (iii) “extending the closing of the Fedwire Funds Service by 30 minutes to 7:00 p.m. ET.” Comments on the proposed amendments are due 60 days after their publication in the Federal Register.
Fed Chair Powell and Fed Governor Brainerd Deliver Remarks at 2019 Federal Reserve System Community Development Research Conference
On 9 May, Fed Chair Powell delivered the welcoming remarks at 2019 Federal Reserve System Community Development Research Conference in a speech entitled “Renewing the Promise of the Middle Class.” Chair Powell discussed three key observations that were of focus atr the conference, including: (i) the “long-term decline in relative income growth and upward economic mobility for those in the middle”; (ii) the “widening gap in economic status and prospects between those with a college degree and those without one”; and (iii) the “prospect of moving up the economic ladder depends on factors beyond effort and talent, including your family, the neighborhood you grow up in, and the quality of the primary and secondary schools you attend.”
On 10 May, Fed Governor Brainard followed Powell at the conference with a speech entitled “Is the Middle Class within Reach for Middle-Income families?” During her speech, Brainard touched upon a number of topics, including: (i) “middle-income families still have not fully recovered the wealth they lost in the Great Recession”; (ii) middle-income households have “limited room to absorb volatility in cash flow” and many are “concerned about the adequacy of their retirement savings”; (iii) “many households find it challenging to make key middle-class investments because incomes at the middle are not keeping up with the rising costs of education and homeownership”; and (iv) “while the strengthening of the labor market over the course of this extended recovery has benefited middle-income families, the long-term decline in the share of national income going to wage earners is concerning.” Brainard concluded that in the “long-term, the shifting of wealth and income to the top of the distribution and away from the middle could pose challenges to the health and resilience of our economy.”
Fed Publishes Supervision and Regulation Report
On 10 May, the Fed published its May 2019 supervision and regulation report regarding banking conditions and the Fed’s supervisory and regulatory activities. The report is published on a periodic basis, typically in conjunction with testimony before Congress by the Fed Vice Chair for Supervision, and focuses on different banking topics. This latest report focuses on how the Fed tailors its supervisory and regulatory programs based on the size and complexity of entities that it regulates. With regards to the current banking conditions, the report indicates that, among other things: (i) “the financial performance of the banking industry is generally strong”; (ii) “banks have expanded lending throughout the economy”; and (iii) “asset quality of the banking industry continues to improve overall.” With regards to regulatory developments, the report indicates that the Fed continues to “identify opportunities to tailor its regulatory framework focusing on efficiency, transparency, and simplicity” and that the Fed has primarily focused the tailoring of its existing framework based on the implementing provisions of the Economic Growth, Regulatory Relief, and Consumer Protection Act. With regards to supervisory developments, the report states that the Fed takes a “risk-focused approach” to supervision and that the primary objective of its supervision framework for large financial institutions is to “enhance the resiliency of the firms while simultaneously reducing the impact to the economy in the event of failure.” In addition, the report explains that the Fed “tailors its regional and community bank supervisory programs in a way that avoids imposing excessive burden.”
o May 13: Comments are due on the Financial Stability Oversight Committee’s proposed interpretive guidance on nonbank financial company designations.
o May 13: Comments are due on the Fed’s notice of advance rulemaking on Regulation D (reserve requirements of depositary institutions).
o May 13: Comments are due on the FDIC’s proposed rule to revise the “Recordkeeping for Timely Deposit Insurance Determination.”
o May 15: Comments are due on the CFPB’s notice of proposed rulemaking that would rescind certain provisions of its regulation governing payday, vehicle title, and certain high-cost installment loans.
o May 15: CFTC Commissioner Stump will address the ICI Global Trading & Markets Committee and Derivatives Markets Advisory Committee.
o May 15: The Senate Banking Committee will hold a hearing on Oversight of Financial Regulators.
o May 15: The House Financial Services Committee’s Subcommittee on Investor Protection, Enterpreneurship and Capital Markets will hold a hearing entitled “Protecting Economic Growth: A Review of Proposals to Strengthen the Rights and Protections for Workers.”
o May 15: The House Financial Services Committee’s Subcommittee on National Security, International Development and Monetary Policy will hold a hearing entitled “Assessing the Use of Sanctions in Addressing National Security and Foreign Policy Challenges.”
o May 16: The House Financial Services Committee will hold a hearing entitled “Oversight of Prudential Regulators: Ensuring the Safety, Soundness, and Accountability of Megabanks and Other Depository Institutions.”
o May 23: OCC will hold a public meeting of its Mutual Saving Association Advisory Committee.