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The FDIC Should Not Allow Commercial Firms to Acquire Industrial Banks
Wilmarth, Arthur E. - 2020
Persistent link: https://www.econbiz.de/10012832724
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Identifying Groups as ‘Financial Conglomerates’ Under European Financial Law (Directive 2002/87/EC) : A Not So Straightforward Exercise
Gortsos, Christos - 2017
The purpose of this paper, structured in three Sections, is twofold: (a) The first is to analyse the conditions under which a group of financial firms is considered to be a ‘financial conglomerate' in accordance with the (complex) definition of this term in Article 2 (point (14)) of the...
Persistent link: https://www.econbiz.de/10012944116
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Comment Letter In Opposition to the OCC's Proposed 'Valid-When-Made' Rule
Wilmarth, Arthur E. - 2020
” for a national bank or a federal savings association, under 12 U.S.C. 85 or 12 U.S.C. 1463(g)(1), “shall not be affected …
Persistent link: https://www.econbiz.de/10012843369
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Comment Letter In Opposition to the OCC's Proposed "True Lender" Rule
Wilmarth, Arthur E. - 2020
Persistent link: https://www.econbiz.de/10012825719
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Policy Brief : The OCC's Repeated Failures to Comply with the Dodd-Frank Act and Other Legal Authorities Governing the Scope of Preemption for National Banks and Federal Savings As...
Wilmarth, Arthur E. - 2021
This policy brief examines several failures by the Office of the Comptroller of the Currency (OCC) to comply with the Dodd-Frank Act and other legal authorities governing the scope of preemption for national banks and federal savings associations. The policy brief argues that the OCC should...
Persistent link: https://www.econbiz.de/10013313569
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We Must Protect Investors and Our Banking System from the Crypto Industry
Wilmarth, Arthur E. - 2023
mandate, and a stronger enforcement record than the Commodity Futures Trading Commission (CFTC).Second, federal bank … in fluctuating-value cryptocurrencies, either on their own behalf or on behalf of others. In addition, federal bank …
Persistent link: https://www.econbiz.de/10014254572
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The OCC's and FDIC's Attempts to Confer Banking Privileges on Nonbanks and Commercial Firms Violate Federal Laws and Are Contrary to Public Policy
Wilmarth, Arthur E. - 2020
firms to undermine fundamental public policies embodied in federal laws governing banks and bank holding companies.In 2018 …, the OCC announced that it would approve national bank charters for “fintech”firms that provide lending and payment … ruled in 2019 that the OCC’s nondepository national bank charter was unlawful. However, in August 2020, Acting Comptroller …
Persistent link: https://www.econbiz.de/10014090002
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Comment Letter to the U.S. Treasury Department Regarding the Risks of Stablecoins
Wilmarth, Arthur E. - 2022
This letter responds to the U.S. Treasury Department’s request for public comments on President Biden’s Executive Order No. 14067, “Ensuring Responsible Development of Digital Assets” (Mar. 9, 2022). This letter contends that (1) digital stablecoins currently pose significant risks to...
Persistent link: https://www.econbiz.de/10013492255
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It's Time to Regulate Stablecoins as Deposits and Require Their Issuers to Be FDIC-Insured Banks
Wilmarth, Arthur E. - 2022
In November 2021, the President’s Working Group on Financial Markets (PWG) issued a report analyzing the rapid expansion and growing risks of the stablecoin market. PWG’s report determined that stablecoins pose a wide range of potential hazards, including the risks of inflicting large losses...
Persistent link: https://www.econbiz.de/10013309420
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The Dark Side of Universal Banking : Financial Conglomerates and the Origins of the Subprime Financial Crisis
Wilmarth, Arthur E. - 2009
Persistent link: https://www.econbiz.de/10013159841