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Federal Reserve System

Jul 23, 2019

Oh How Will We Measure When the Ruler is Uncertain: More Observations on the LIBOR Saga

At the end of May, I wrote a piece titled “‘Measure for Measure’ LIBOR, SOFR, and the U.S. DOLLAR.  ICE BANK YIELD INDEX”.  As noted there, the U.S. Board of Governors of the Federal Reserve System (“FRB”) in 2014 created the Alternative Rates Reference Committee (“ARRC”) to develop alternatives to LIBOR. » Read More

May 14, 2019

“Control” – Objective and Subjective: The Jurisdiction of the Federal Reserve and Fintech Investments

Although the American banking system is hardly a model of straightforward simplicity at best (at least five primary federal regulators, depending upon the type of bank or whether a savings institution is involved, and not forgetting credit unions, let alone the 50 state bank chartering and regulating authorities), one area of almost impenetrable opaqueness has been the issue of when one company “controls” another company under the Bank Holding Company Act or the Home Owners’ Loan Act (sometimes called the Savings and Loan Holding Company Act).» Read More