12.17.2010

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Updates

FDIC Approves Collins Amendment

On Tuesday, December 14, 2010, the Board of Directors of the FDIC approved an interagency rule implementing certain provisions of Section 171 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, commonly referred to as to the Collins Amendment.  The Collins Amendment requires capital requirements applicable to insured banks to "serve as floor for other capital requirements the agencies establish."  Basel II, as it is, allows for reductions in risk-based capital requirements below those applicable to insured banks, and will need to be altered.

Read the FDIC press release

The Fed Proposes Rules to Expand Consumer Protection

One Monday, December 13, the Federal Reserve Board proposed two rules expanding consumer protection coverage for credit transactions and leases with higher dollar amounts.  The proposed rules would alter Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing).  The Dodd-Frank Wall Street Reform and Consumer Protection Act requires that consumer protections be increased for consumer credit transactions and consumer leases to include transactions up to $50,000, higher than the $25,000 threshold currently in place.

Read the Federal Reserve Press Release

Office of Financial Research Issues Statement on Legal Entity Identification for Financial Contracts

The newly established Office of Financial Research ("OFR") under the Dodd-Frank Wall Street Reform and Consumer Protection Act recently issued a statement of policy.  The OFR, housed at the Department of Treasury, has the express authorization to collect data for the Financial Stability Oversight Council and establishes standards for the reporting of such data.

Read the OFR's Statement of Policy

The Fed Proposes Rules to Limit Debit Card Transaction Fees

On Thursday, December 16, the Federal Reserve proposed rules aimed at limiting interchange fees for debit card transactions.  The Dodd-Frank Wall Street Reform and Consumer Protection Act requires that the Federal Reserve ensure that such transaction fees are "reasonable and proportional to the cost incurred by the issuer."  The proposed Federal Reserve rules cap these fees at 12 cents per transaction.  In addition, the proposed rules also contained restrictions on transaction routing and network exclusivity.  Comments on the proposed rules are due by February 22, 2011.

Read the Federal Reserve Press Release

The SEC Proposes Disclosure Rules Regarding Conflict Minerals, Mine Safety and Resource Extraction Issuers

On Wednesday, December 15, the SEC proposed new disclosure rules regarding the use of conflict minerals originating in the Democratic Republic of Congo or an adjoining country, mine safety information and health standards, and payments made to the United States or foreign governments by resource extraction issuers.  These proposed rules are mandated by certain sections of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Read the SEC press release regarding the use of conflict minerals

Read the SEC press release regarding mine safety

Read the SEC press release regarding resource extraction issuers

© 2010 Perkins Coie LLP


 

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