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Abstract: 

In this article, the authors discuss the Federal Reserve’s role in supervision and enforcement, give a brief history of financial holding company activities, and describe the post-crisis regulatory response. They then highlight the use by the Federal Reserve of confidential section 4(m) agreements as a “shadow” policy tool to reign in activities it deems to be risky. They close by noting a recent speech by Vice-Chair Quarles proposing specific reforms to increase transparency of the bank supervisory process.

Keywords: “Confidential Supervisory Information” (“CSI”); “Matters Requiring Attention” (“MRA” Letters); Federal Reserve 4(M) Agreements

Affiliations:  1: Milbank LLP; 2: Milbank LLP.