Roadmaps

• The Federal Reserve released a final liquidity coverage ratio (LCR) rule.
• GAO released a report on the complex U.S. financial regulatory framework.
• OCC released a quarterly Mortgage Metrics report.

• On January 19, 2016, Treasury requested public comment on the evolving structure of the U.S. Treasury market.
• NCUA and Treasury announced an agreement to streamline the application process for low-income credit unions to become certified as Community Development Financial Institutions (CDFIs).

This is a very detailed Roadmap that tracks all of the legislative initiatives that are pending in the U.S. Congress.

As you will see, there is shortage of ideas to both reform the new consumer protection agency, as well alter the laws that it administers.

This is a Working Document, so it will be updated from time-to-time as additional legislation is introduced and considered.

Since this is a lengthy document, the cover page has instructions on how to navigate this Roadmap.  There is also a Table of Contents that we hope will be useful to you, as well.

Yesterday, the Senate Banking Committee reported out of Committee the Financial Regulatory Improvement Act of 2015.  Attached please find an updated Roadmap that includes the provisions that were included in Chairman Shelby’s Manager’s Amendment that was passed yesterday in Committee.  

As noted in an e-mail note yesterday, the following is a summary of the Committee proceedings yesterday:

• The Democratic Substitute failed by on a party-line vote of 10 to 12.
• Senator Crapo's amendment #19 passed by a vote of 13 to 9, with Senator Donnelly supporting the Republican amendment.   It would prohibit federal banking and credit union regulators from implementing or participating in the Department of Justice's Operation Choke Point Initiative.  Senator Crapo dubbed his amendment the "Tom Cruise" amendment after a brief explanation of/comparison to the movie "Minority Report," which was very amusing.  
• Senator Toomey offered his Amendments #3, #4, #8, and #11.   He offered and then withdrew three of the four amendments, requesting a recorded vote on Toomey Amendment #8 that would increase from $10 billion to $50 billion, the threshold for direct examination.   Amendment #8 was adopted by a vote of 13 to 9, with Senator Donnelly supporting the Republican amendment. 
• Senator Vitter offered and withdrew his amendments #14 and #16.   #14 would limit the compensation for nongovernmental directors of the Board of Directors of Securities Investor Protection Corporation.  Ranking Member Brown noted that he would support the goal of the amendment but not vote for it in Committee.  Senator Vitter noted that the Committee will likely hold a hearing on Amendment #14 in the future.     #16 would address equity capital requirements for the “Too Big to Fail” entities.   Again, Senator Vitter offered and withdrew his Amendment #14 and Amendment #16.   He did not offer his two other amendments. 
• The Financial Regulatory Improvement Act of 2015 passed by a vote of 12 to 10.  

Both sides of the aisle agreed much work is left to be done before the bill makes it to the Senate Floor.

Regards,

Canfield Press

This Roadmap compares the Chairman’s mark to the Democratic substitute legislation, scheduled for markup May 20, 2015. It is a working draft that will be updated as the legislation proceeds through the legislative process.

The Chairman’s mark is considerably longer than the Democratic substitute, so a side-by-side comparison would be difficult for a review of much of the Chairman’s mark. For ease of reading, this Roadmap contains a side-by-side of areas of overlap, and a standalone description of the entire Chairman’s mark. More specifically, first there is a side-by-side comparing the Democratic substitute with the comparable provisions in the Chairman’s mark. 

Where both bills are identical, or nearly so, the side-by-side has only one column. The side-by-side includes all provisions in the Democratic substitute even if there is no comparable provision in the Chairman’s mark, but does not contain provisions in the Chairman’s mark for which the Democratic substitute has no comparable provision. Following the side-by-side is a comprehensive description of all of the Chairman’s mark, including its technical corrections to the Dodd-Frank Act.

Also attached is the list of amendments that are expected to be offered at tomorrow’s Senate Banking Committee markup.  If the amendments are adopted, we will include them in an updated Roadmap.

We hope you find this useful. 

Best regards,

Canfield Press

American entrepreneur Marc Andreessen

Regulation C and its Commentary as Proposed to be Amended.

The Uniform Law Commission holds its annual meeting July 11 through 17, 2014.   It will discuss its draft Uniform Home Foreclosure Procedures Act.

Attached please find an updated Roadmap to GSE Reform.  This update reviews all of the pending GSE reform bills that have been introduced in the U.S. Congress to date.

Best regards,

Anne Canfield

 This Roadmap compares the servicing reforms in the 50-state settlement agreements with large servicers to the final servicing rules that the Consumer Financial Protection Bureau published in the Federal Register on February 14, 2013