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SEC Issues No-Action Relief On Registered Funds' Custody Of Loan Interests | Goodwin

REGULATORY DEVELOPMENTS
On February 4, the SEC published a request for public comment regarding potential reform measures for money market funds, as highlighted in a recent report of the President’s Working Group on Financial Markets (PWG). The PWG report discussed the results of the PWG’s study on the effect of the COVID-19 pandemic on the short-term funding markets and, in particular, on money market funds, including the general stress experienced by prime and tax-exempt money market funds. The report concluded that the events of March 2020 show that more work is needed to reduce the risk that structural vulnerabilities in prime and tax-exempt money market funds will exacerbate or lead to stresses in short-term funding markets. The potential reform measures as outlined in the PWG report seek to: (i) address money market funds’ structural vulnerabilities that can contribute to stress in short-term funding markets; (ii) improve the resilience of money market funds and br ....

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SBA and Treasury Department Issue New Guidance on PPP | Goodwin

In this Issue. The Office of the Comptroller of the Currency (OCC) issued guidance on its authority to charter limited purpose trust companies, raising the possibility that a limited. ....

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FDIC Finalizes Brokered Deposits and ILC Rules Ahead of the Holidays | Goodwin

REGULATORY DEVELOPMENTS
On December 15, the FDIC approved a final rule to revise and modernize its regulations relating to brokered deposits. The final rule establishes a new framework for analyzing whether deposits made through deposit arrangements qualify as brokered deposits, including those between insured depository institutions (IDIs) and third parties, such as financial technology companies. Specifically, the final rule:
Clarifies when a person meets the deposit broker definition in a way that provides clear rules by which banks and third parties can evaluate whether particular activities cause deposits to be considered brokered;
Identifies a number of bright-line categories (called “designated exceptions” which include deposits where the agent has less than 25% of the total “assets under administration” for its customers; health savings accounts; deposits related to certain real estate and mortgage servicing transactions; certain retirement funds; and c ....

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