What's Next for Dodd-Frank Implementation?

So far, the Federal Reserve System has completed dozens of initiatives between August 2010 and March 2011 for compliance with provisions of the Dodd-Frank Act. Some of the proposals that the Fed will seek public comment on between April and June 2011 include:

Registration of Nonbank Financial Companies Designated for Consolidated Supervision

The Board will request comment on a proposed rule to prescribe the forms and information requirements for nonbank financial companies designated for enhanced, consolidated supervision by the Federal Reserve to register with the Board.

Credit Rating Alternatives

The Board will request comment on changes to existing rules to implement the requirements of section 939A of the Dodd-Frank Act relating to use of credit ratings in agency rules.

Credit Rating Alternatives for Bank Financial Subsidiaries

The Board will request comment on a proposed rule, developed with the U.S. Department of the Treasury, to replace the investment grade rating requirement that applies to financial subsidiaries of national and state member banks with an alternative standard.

Supervisory Standards Applicable to Savings and Loan Holding Companies

The Board will request comment on a proposed rule to apply certain requirements of financial holding companies to savings and loan holding companies that engage in financial activities permissible only to a financial holding company. These requirements will include companies being well capitalized and well managed, as well as adhering to the Community Reinvestment Act.

Volcker Rule: Activity Restrictions

The Board, along with other federal financial regulatory agencies, will request comment on a proposed interagency rule to implement the Volcker Rule’s restrictions on proprietary trading, hedge fund and private equity fund activity by insured depository institutions and their affiliates (including bank holding companies).

Resolution Plan (“Living Will”) Requirement

The Board will request comment on a proposed rule developed jointly with the FDIC to implement the “living will” requirements for nonbank financial companies supervised by the Board, as well as BHCs with $50 billion or more in assets.

Credit Exposure Reporting Requirement

The Board will request comment on a proposed rule developed jointly with the FDIC to require nonbank financial companies supervised by the Board and bank holding companies with $50 billion or more in assets to report to the Board, FSOC and FDIC on the credit exposures between the company and other “significant” nonbank financial companies and bank holding companies.

Remittance Transfers

The Board will request comment on a proposed rule to:

  • require new disclosures from remittance transfer providers, including written notices, receipts and statements detailing transaction specifics;
  • establish standards for remittance transfer errors, cancellations and refunds;
  • establish standards for liability of remittance transfer providers, including agents; and
  • address the issue of how remittance transfer providers should disclose the amount of currency to be received in a foreign country when that amount is unknown.

Stay up to date on the latest in the Dodd-Frank rule-writing process at the St. Louis Fed’s Dodd-Frank Regulatory Reform Rules site.

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