Editor's Note: This is a monthly publication on economic trends and financial policy issues. In this publication you can read "The Longbrake Letter", an analysis of economic trends and conditions written by Bill Longbrake, as well as commentary on financial regulation and policy written by members of the law firm Barnett, Sivon & Natter, P.C., a Washington, DC based law firm that specializes in financial services law. The lawyers in the firm are also counsel to the international law firm, Squire Patton Boggs.

ISSUE: #64, October 2015

The Longbrake Letter
- Bill Longbrake
After a turbulent August and September, a semblance of calm has returned to global financial markets. Fears that China is on a verge of economic Armageddon have subsided. Policy makers have soothed markets by doubling down on monetary stimulus. The fundamentals were never as troublesome as the market feared. But they aren't great either. Growth is slowing everywhere, including the U.S. where soft third quarter growth is probable. Inflation is hard to find. Slow growth and low inflation is the order of the day. The only good news is that recession is probably not imminent. This month's letter includes an examination of the impact of macroeconomic trends on long-term rates of return on Investments and discusses the consequences of a persistent low-inflation/low-growth environment and the challenges that would pose for fiduciaries who are responsible for pension funds and endowments.

- Bob Barnett
The District Court for the District of Columbia recently granted a preliminary injunction to a foreign bank that had been the subject of a rule that would prevent it from establishing any correspondent relationship with any dollar bank. The injunction was granted on a failure of FinCEN to follow the dictates of the Administrative Procedure Act in that it withheld non-confidential or privileged information from the bank and did not explain why it did not use less severe penalties.

Designing New Products in the CFPB Era
- Jim Sivon and Katie Wechsler
In the past year, we have had a number of clients express frustration over the development of new products and services. Regulatory uncertainty and risks, especially associated with the CFPB, have become stumbling blocks for many financial institutions. In an effort to remove some of this mystery, we have outlined ten practical tips on how institutions should think about regulatory risks so they can continue to be innovative and meet the evolving needs of their customers.