by Margaret E. Tahyar and Ledina Gocaj
Left to right: Margaret E. Tahyar and Ledina Gocaj (Photos courtesy of Davis Polk & Wardwell LLP)
On June 6, 2023, the Federal Reserve, FDIC and OCC (the Agencies) released final interagency guidance on banking organizations’ management of risks associated with third-party relationships. Davis Polk’s memo on the guidance is linked here. Our key takeaways:
Editor’s Note: The NYU School of Law Program on Corporate Compliance and Enforcement (PCCE) is watching the recent banking crisis and failures of Silicon Valley Bank, Signature Bank, and, most recently, First Republic Bank. PCCE is looking to publish additional posts in this area and those interested should contact joseph.facciponti@nyu.edu.
by Dana Seesel Bayersdorfer, Jung Eun Choi, Luigi L. De Ghenghi, Ledina Gocaj, Randall D. Guynn, Eric McLaughlin, Daniel E. Newman, David L. Portilla, Gabriel D. Rosenberg, and Margaret E. Tahyar
From top left to right: Dana Seesel Bayersdorfer, Jung Eun Choi, Luigi L. De Ghenghi, Ledina Gocaj, and Randall D. Guynn.
From bottom left to right: Eric McLaughlin, Daniel E. Newman, David L. Portilla, Gabriel D. Rosenberg, and Margaret E. Tahyar. (photos courtesy of Davis Polk & Wardwell LLP)
The Federal Reserve and the FDIC reports on their supervision of Silicon Valley Bank and Signature Bank provide insight into potential upcoming shifts in regulatory and supervisory focus.
The Board of Governors of the Federal Reserve System (Federal Reserve or Board) released the results of its review of the supervision and regulation of Silicon Valley Bank (SVB), which was led by Vice Chair for Supervision Michael S. Barr (the Board Report),[1] and the FDIC released the results of its review of the supervision of Signature Bank,[2] which was led by FDIC Chief Risk Officer E. Marshall Gentry (the FDIC Report).[3]