- The federal government expects banks to get a lot more serious about cybersecurity. For the first time in history, the US Treasury Secretary has criticized the nation’s safeguards to protect against cybersecurity attacks on our financial infrastructure. In response, the Federal Financial Institutions Examination Council (FFIEC) took three initial steps to increase awareness in the US banking system.
- On July 21, 2014, the Federal Deposit Insurance Corporation (FDIC) issued Financial Institution Letter FIL-40-2014. The guidance clarifies how the FDIC will evaluate requests by S-Corporation banks to make shareholder dividend payments to cover taxes on their pass-through share of the bank's earnings. Without FDIC approval, these dividends would not be permitted under the capital conservation buffer requirements in the Basel III rule.
- As a result of additional regulatory requirements, merger and acquisition discussions and activity are increasing in the banking industry. Associated transaction costs incurred related to a merger or acquisition transaction can be significant. These costs can include fees for financial advice, legal services, due diligence services, and expenses to arrange debt financing and can greatly impact a company’s financial statement.
- In June 2014, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued an addendum to the “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure”.
- For years, risk governance meant risk management, with a relatively narrow focus on specific areas: loans, legal, and possibly IT. Then, everything went sideways in 2008-2009, and regulators saw the need for a more proactive, comprehensive risk governance strategy. Within the past five years, new rules and guidelines have begun changing the flaws regulators could see boards of directors were not engaged at the right level; board members and executives weren’t getting the right information to make informed decisions; and management didn’t have tools in place to facilitate a timely and comprehensive analysis of overall risk.
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