@Regulatory Newsletter – October 2009 |
Publish date:
The October issue of @Regulatory addresses topics of interest for banking and investment management professionals.
Banking: The Office of the Comptroller of the Currency, the Office of Thrift Supervision, the Federal Deposit Insurance Corporation, and the Federal Reserve Board of Governors (the Agencies), have published proposed guidance and a request for comment on “Correspondent Concentration Risks” in the Federal Register. This proposed guidance addresses the regulators’ expectations with regard to financial institution identification, monitoring and management of risks associated with concentrations arising in correspondent relationships. The focus of the guidance is on financial institutions’ aggregate credit and funding exposures and the article reviews the major points found in the guidance plus specific areas of interest which the Agencies are seeking comments on.
Investment Management: The U.S. Securities and Exchange Commission (SEC) recently released for public comment IA-2910, Political Contributions by Certain Investment Advisers, commonly referred to as the proposed “pay-to-play” rule under the Investment Advisers Act of 1940. The proposed rule seeks to curb the influence registered investment advisers may have on their selection to manage public monies based on political contributions. According to the SEC, the decision to choose one adviser over another may be influenced by the level of political contributions made to a certain official or campaign. This practice may result in financial loss to the end beneficiary due to poor fund management, increased management fees or other, similar negative impacts. In an effort to curb “pay-to-play” practices, the proposed rule focuses on a number of restrictions, described in “The SEC Proposes to Restrict “Pay-to-Play” Practices.”
We also have highlighted in our News Bulletins selected policy and supervisory guidance issues that are posing challenges across the banking and investment management sectors.
Banking
- Federal Reserve Board Proposes Rules Implementing Regulation Z
- Suspicious Activity Reports (SARs) Regarding Troubled Asset Relief Program (TARP)-related Programs
- Financial Crimes Enforcement Network (FinCEN) SAR Activity Review
Investment Management
- Legislative Initiatives to Require Private Advisers to Register with the SEC
Read the full issue in the PDF attached below.


@Regulatory Newsletter – October 2009