Insights
Partner Christian Brockman is attending.
Read the latest edition of On-Chain Spotlight for key regulatory, market, and litigation developments shaping the blockchain and digital assets industry.
On June 30, 2026, the Securities and Exchange Commission issued a Request for Comment seeking public input on exchange‑traded funds that invest in innovative asset classes or engage in novel investment strategies (including crypto assets, commodity‑focused instruments, single stock strategies, heightened leverage, blockchain‑enabled opportunities, private assets, event contracts, or a combination of any of the above).
-
Read the latest edition of On-Chain Spotlight for key regulatory, market, and litigation developments shaping the blockchain and digital assets industry.
-
Read the latest edition of On-Chain Spotlight for key regulatory, market, and litigation developments shaping the blockchain and digital assets industry.
-
Read the latest edition of On-Chain Spotlight for key regulatory, market, and litigation developments shaping the blockchain and digital assets industry.
On June 11, 2026, the United States Supreme Court issued its decision in FS Credit Opportunities Corp., et al. v. Saba Capital Master Fund, Ltd., et al., holding that Section 47(b) of the Investment Company Act of 1940 does not create an implied private right of action. The decision is significant for investment companies registered under the 1940 Act because it clarifies that Section 47(b) empowers courts to rescind a contract but does not create a separate private right of action to seek such remedy, while leaving intact the SEC’s enforcement authority under the 1940 Act.
In Oregon Environmental Council v. IRS, issued on June 6, 2026, the US District Court for the District of Columbia held that IRS Notice 2025-42—which eliminated the longstanding 5% safe harbor method for establishing “beginning of construction” for wind and large-scale solar facilities—is arbitrary and capricious under the Administrative Procedure Act, and accordingly the Court vacated the Notice in full and remanded the matter to the IRS for further administrative action.
-
Read the latest edition of On-Chain Spotlight for key regulatory, market, and litigation developments shaping the blockchain and digital assets industry.
-
The United States Securities and Exchange Commission has announced that it plans to completely rescind the climate disclosure rules that it finalized just two years ago. The rules, entitled The Enhancement and Standardization of Climate-Related Disclosures for Investors, require that companies provide significant new climate-related disclosures in their annual reports and registration statements. Disclosure obligations were originally set to begin in 2026 and 2027; however, the SEC never implemented the Climate Disclosure Rules due to legal challenges and other delays.
- Topic: The Fed
39 matches.
Our March 31, 2026, Client Alert described the ERBA NPR and SA NPR issued by the federal banking agencies on March 19, 2026. In that Alert, we indicated we would issue a separate Client Alert describing in more detail how the Standardized Approach “risk weights” in Section 32 and “credit conversion factors” (CCFs) in Section 33 of the US Basel III rule would be amended by the proposals in the SA NPR and how those would differ from the risk weights and CCFs proposed in the ERBA NPR (which would be contained in proposed new Sections 111 and 112 of the US Basel III rule). This Alert provides that description and is intended to be read in conjunction with the earlier Client Alert, which provides the background, and defined terms, for this supplementary Client Alert.
Our March 25, 2026 Client Alert “Federal Banking Agencies Issue Revised Basel III Endgame Notices of Proposed Rulemaking and Proposed Amendments to Existing Standardized Approach” described that the three federal banking agencies jointly issued two “notices of proposed rulemaking” captioned “Regulatory Capital Rule: Category I and II Banking Organizations, Banking Organizations With Significant Trading Activity, and Optional Adoption for Other Banking Organizations” and “Regulatory Capital Rules: Regulatory Capital and Standardized Approach for Risk-weighted Assets."
On March 19, 2026, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency issued for comment joint Notices of Proposed Rulemaking proposing changes to the US bank capital regulations. The NPRs propose several changes to the regulations for determining required capital for bank securitization exposures and additional changes that will impact securitization exposure capital charges. While the proposed changes impact banks originating both traditional and synthetic securitizations of their own assets, and securitization exposures in the form of derivatives, and provide a new method for determining the risk weights of exposures to non-performing loan securitizations, this Client Alert focuses on the impact of the proposed rules on banks investing in securitization transactions (other than NPL securitizations), both by buying asset-backed securities with the intent to hold such securities and by providing financing of securitizations by making loans or entering into asset purchase facilities, either directly or through credit and liquidity facilities provided to asset-backed commercial paper conduits.
On March 19, 2026, the three federal banking agencies jointly issued two separate “notices of proposed rulemaking” proposing a revised “expanded risk-based” approach to replace the ERBA proposed in 2023 and amendments to the existing “standardized approach” in the US Basel III rule to reduce risk weights for some exposures, eliminate certain capital deductions, and make other changes to the SA.
In 2017, the UK authority that oversees the London interbank offered rate, announced that LIBOR may be phased out after the end of 2021. The announcement applied to all currency and term variants of LIBOR, including US dollar denominated LIBOR.
The Federal Reserve has established the Main Street Loan Program to provide support to small and medium-sized businesses that were in sound financial condition before the onset of the COVID-19 pandemic.
On June 11, the Federal Reserve Bank of New York issued an updated Notice of Interest for the Municipal Liquidity Facility to reflect the expansion of eligibility for the facility.
On June 3, the Federal Reserve announced expanded eligibility for its Municipal Liquidity Facility. Under the new terms, a State that does not have at least two total counties or cities that meet the minimum population requirements will be able to identify a city or county to be an Eligible Issuer.
The Federal Reserve today issued an amended term sheet establishing pricing criteria for its Municipal Liquidity Facility last described in our April 29 Client Alert. The Federal Reserve Bank of New York also issued today a revised FAQs for the facility.
- May 7, 2020 (Updating an April 14, 2020 Client Alert)
This alert explores the three loan facilities constituting the Main Street Lending Program: the newly announced Main Street Priority Loan Facility, the revised Main Street New Loan Facility, and the revised Main Street Expanded Loan Facility.
On May 5, federal banking regulators adopted an interim final rule that neutralizes the liquidity coverage ratio impact for banks participating in the Federal Reserve’s Money Market Mutual Fund Liquidity Facility and the Paycheck Protection Program Liquidity Facility.
On April 27, the Federal Reserve issued a press release announcing changes to the Municipal Lending Facility described in previous client alerts. At the same time, the Federal Reserve Bank of New York, as sole Reserve Bank lender for the facility, issued a FAQs for the facility.
- April 22, 2020 (Updating an April 13, 2020 Client Alert)
On April 9, the Federal Reserve issued term sheets for six “new” funding facilities under the CARES Act. This client alert describes in detail the Municipal Liquidity Facility.
On April 9 the Federal Reserve issued term sheets for six “new” funding facilities under the CARES Act. Three of those facilities provide for direct loans to companies.
On April 9, 2020, the Federal Reserve released a revised term sheet for TALF 2020 that, among other things, broadens the range of assets that qualify as eligible collateral under the program.
Earlier today the Federal Reserve announced it would establish six new funding facilities supported by Treasury funding authorized by Section 4003(b)(4) of the CARES Act.
The Federal Reserve has established a webpage that provides links to a FAQ and other documents for the Money Market Fund Liquidity Facility described in earlier Chapman client alerts.
Yesterday the Federal Reserve announced it was temporarily removing Treasury securities and deposits at Federal Reserve Banks from the supplementary leverage ratio applicable to Category I-III bank holding companies or US intermediate holding companies of foreign banks.
On March 23, the Federal Reserve announced the establishment of the Term Asset-Backed Securities Loan Facility to support the flow of credit to consumers and businesses.
On March 23, the Federal Reserve issued further amendments to add negotiable certificates of deposit and all short-term municipal securities to the list of eligible collateral.
On March 23, the Federal Reserve added municipal issuers and amended the pricing for the commercial paper funding facility announced on March 17 and issued other “program terms and conditions” posted on the website of the Federal Reserve Bank of New York.
This morning, the Board of Governors of the Federal Reserve System announced sweeping actions to help the economy.
On March 18, the Federal Reserve announced a Money Market Fund Liquidity Facility to make loans to banks and certain affiliates secured by certain assets acquired from “prime” money market funds. Earlier today, the Federal Reserve issued amendments to the program.
On March 17, the Federal Reserve Board announced the establishment of two emergency funding facilities that closely mirror facilities established in 2008 during the last financial crisis in providing liquidity to both short and long term funding markets.
- The Banking Law Journal
This article outlines the features of proposals to adjust the applicability of certain capital and liquidity tests and certain enhanced prudential standards for bank holding companies.
On August 22, the three federal banking agencies issued an interim final rule implementing the May 2018 banking law’s requirement that investment grade, liquid and readily marketable municipal obligations be treated as Level 2B “high quality liquid assets” under the liquidity coverage ratio rule.
On May 22, the House passed Senate bill S. 2155, which would amend certain Dodd-Frank provisions and, primarily for smaller banks and credit unions, provide additional regulatory relief. President Trump is expected to sign the bill, so that it will take effect as law.
The US Court of Appeals for the District of Columbia Circuit recently issued a decision in a case that involved a question of whether the risk retention requirements imposed by Section 941 of the Dodd-Frank Act required open market CLO managers to retain risk in those transactions they managed.
On April 19, the House Financial Services Committee posted a “discussion draft” of a revised version of the CHOICE Act. The discussion draft contains most of the provisions in last year’s bill with a number of important changes.
- February/March 2017Pratt's Journal of Bankruptcy Law
With Republicans retaining control of both chambers of Congress and Donald Trump elected President, the prospects for financial regulatory reform have changed. Many observers point to the Financial CHOICE Act as the best indication of Republican Congressional aspirations for such reform.
- Spring/Summer 2016 (Originally Published April 7, 2016)Real Estate Finance Journal
The Board of Governors of the Federal Reserve adopted a final rule to include certain U.S. municipal securities as high-quality liquid assets for purposes of the liquidity coverage ratio rule to which large banks are subject.
- June 2016AIRA Journal
This article discussed leveraged lending guidelines, unitranche facilities and the risks associated with unitranche facilities, including with respect to “agreements among lenders” as illustrated by the recent case of In re Radio Shack Corporation.
The Board of Governors of the Federal Reserve System issued a Notice of Proposed Rulemaking re-proposing a rule that would establish credit limits for single counterparties ofU.S. bank holding companies, foreign banking organizations, and U.S. intermediate holding companies of an FBO.
- Client Alert
On March 4, 2016 the Board of Governors of the Federal Reserve System issued a Notice of Proposed Rulemaking re-proposing a rule that would establish credit limits for single counterparties ofU.S. bank holding companies, foreign banking organizations, and U.S. intermediate holding companies of an FBO, with $50 billion or more of consolidated assets.
- Client Alert
To kick off the Memorial Day weekend, the Federal Reserve Board announced a proposal to include certain state and municipal general obligation bonds in the calculation of High Quality Liquid Assets, the numerator of the new Liquidity Coverage Ratio requirement to which large banks are subject.
In September 2014, the U.S. banking agencies adopted final rules implementing a liquidity coverage ratio requirement that will test a bank's ability to withstand "liquidity stress periods." In collaboration with the Structured Finance Industry Group (SFIG), Chapman attorneys authored a guide summarizing elements of the final rule that have the greatest impact on the securitization market.
On September 3, 2014, the US banking agencies adopted final rules implementing a liquidity coverage ratio (LCR) requirement that will test a bank's ability to withstand liquidity stress periods. The specific objective of the LCR rules is to ensure that a bank has enough high quality liquid assets (referred to as HQLA) that can be immediately converted into cash to meet its liquidity needs for a 30-day stress period.
- Client Alert
On October 24, 2013, the Board of Governors of the Federal Reserve Board released a proposed rule that introduces a liquidity coverage ratio requirement that will test a bank's ability to withstand "liquidity stress periods."
