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U.S. Financial Regulators Continue Focus on Bank-Fintech Partnerships through Guidance and Request for Information

On July 25, 2024, the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a joint statement describing potential...more

Operational Resilience Requirements May Be Coming for Large U.S. Banks Soon

On March 12, 2024, Acting Comptroller of the Currency Michael Hsu indicated in a speech that regulations may soon be forthcoming that would be designed to bolster larger depository institutions’ ability to withstand...more

U.S. Financial Regulators Propose Rule that Supervisory Guidance Does Not Equal Law

On October 20, 2020, a consortium of U.S. federal financial regulators (Regulators), issued a proposed rule (Proposed Rule) that, if enacted, would codify that mere supervisory guidance that is not the product of notice and...more

The Fed May Increase Cybersecurity Standards for Large Financial Institutions and their Service Providers

The Board of Governors of the Federal Reserve System has recently indicated it may move forward with enhanced cybersecurity standards that had previously been floated by the Board, the Office of the Comptroller of the...more

The Deadline Looms for New York Cybersecurity Regulations Vendor Compliance Requirements

Financial institutions regulated by the New York Department of Financial Services (DFS)—referred to in this post as “Covered Entities”—should by now be well familiar with the department’s sweeping cybersecurity regulation, 23...more

Has the Era of the Consumer Class Action Waiver Passed?

Financial Institutions may need to revise consumer contracts to remove class action waivers in preparation for a March 2018 federal rule. On July 19, the U.S. Consumer Financial Protection Bureau, the federal regulator for...more

Sweeping New York Cyber Regulations Hit Financial Institutions March 1: Time to Look at Those Vendor Relationships

Effective March 1, 2017, first-in-kind regulations issued by the New York Department of Financial Services (New York DFS) will begin to affect a wide array of both depository and non-depository financial institutions. The new...more

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