Client Alert

The Dodd-Frank Wall Street Reform and Consumer Protection Act: Impact on Banks

July 16, 2010

V. Gerard Comizio and Lawrence D. Kaplan

This StayCurrent bulletin addresses the impact of the Dodd-Frank Act on national and state-chartered banks. As described below, the Dodd-Frank Act imposes significant changes on the supervision and operations of all types of charters. In pertinent part, the key impact of the Dodd-Frank Act is to create a system of differential regulation based on asset size, with smaller banks, both national-and state-chartered, being subject to different regulatory regimes than applicable to larger institutions. As discussed below, individual sections of the Dodd-Frank Act have different triggers to distinguish between small and large banks, with various changes in regulatory focus being triggered between $10 and $15 billion in assets.

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