Michael Escue Authors Banking Column in New York Law Journal

March 30, 2012
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On March 30, Mr. Escue wrote “Federal Reserve Approvals Offer Insight into New Financial Stability Analysis” for the New York Law Journal. In his inaugural banking law column, Mr. Escue examines the Federal Reserve’s approvals of the acquisition of RBC Bank (USA) by The PNC Financial Services Group, Inc. and the acquisition of ING Bank, fsb by Capital One Financial Corporation. As the Fed’s first articulations regarding the “financial stability” factor added to the Bank Holding Company Act of 1956 by the Dodd-Frank Wall Street Reform and Consumer Protection Act, the orders approving these transactions are insights into how the Fed will consider the financial stability factor when acting on applications involving banks and non-bank acquisitions.