On November 20, the New York State Department of Insurance announced that it will delay indefinitely the application of New York Insurance Law to credit default swaps, which would regulate certain credit default swaps as insurance products.  Orrick Client Alert.

On November 21, the Office of the Comptroller of the Currency announced that a new national bank “shelf charter” would be available for private investors in troubled depository institutions. Previously, only depository institutions and their holding companies could participate in FDIC auctions of failed banks and thrifts.  Orrick Client Alert. OCC Press Release.