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The Board of Governors of the Federal Reserve System ("FRB") provided aggregate global indicator amounts for 2018. The indicator amounts are used in the calculation of risk-based capital surcharges for global systemically important bank ("GSIB") holding companies. The FRB stated that the methodology uses five categories that are proportional to systemic importance: an institution's size, interconnectedness, substitutability, complexity and cross-jurisdictional activity.

The Consumer Financial Protection Bureau ("CFPB") proposal to (i) streamline the no-action letter process and (ii) create a CFPB Product Sandbox was published in the Federal Register. Comments must be received before February 11, 2019. As previously covered, the goals of the proposal are as follows: to (i) streamline the application process for the filing and review of applications for no-action letters; (ii) expand the types of statutory and/or regulatory relief; (iii) "specify[] procedures for an extension where the relief initially provided is of limited duration"; and (iv) "provid[e] for

Steven Lofchie Commentary by Steven Lofchie

SEC Chair Jay Clayton and SEC Commissioner Kara M. Stein highlighted (i) the increasing number of investor requests for improved environmental, social and governance ("ESG") disclosures, and (ii) the need to improve the arbitration awards process. In remarks to the SEC Investor Advisory Committee, Mr. Clayton stated that the agency observed an increasing number of issuers disclosing ESG information and requests for ESG information by investors. He argued that (i) companies should focus on providing material disclosures that investors need in order to make informed investment and voting

Steven Lofchie Commentary by Steven Lofchie

SEC Commissioner Robert J. Jackson Jr. urged regulators to create greater transparency as to proxy voting by institutional investors, particularly index funds and other passive investors. Mr. Jackson stressed that such institutional investors cast votes in corporate elections on behalf of more than 100 million families that own shares in funds. In testimony before the Federal Trade Commission Hearing on Competition and Consumer Protection, Mr. Jackson asserted that "we are at a crucial moment in financial history, with corporate elections now being decided by only a handful of index fund

FinCEN extended the deadline for certain individuals to file Foreign Bank and Financial Accounts Reports ("FBAR"). This affects individuals with signature authority over, but no financial interest in, a foreign financial account. The filing due date has been extended to April 15, 2020. The original expiration date was April 15, 2018.