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Morgan Lewis Urges NYDFS to Modify Its Re-Proposed Cybersecurity Rules

Morgan Lewis submits second comment letter on the proposed rules. The New York State Department of Financial Services (DFS) is expected soon to issue “first-in-the-nation” cybersecurity regulations that will apply to...more

Executive Order Could Lead to Changes in the Regulation of US Financial Markets

President Trump’s order sets forth core regulatory principles and requires an extensive report in 120 days, which could lead to broader changes in the regulation of the US financial markets....more

NYDFS Modifies, Delays Implementation of Cybersecurity Rules

The modified rules, which still remain among the most prohibitive, could be adopted in final form as early as this month. Since September 2016, the New York State Department of Financial Services (DFS) has been...more

Morgan Lewis Urges NYDFS to Modify Proposed Cybersecurity Rules

The New York Department of Financial Services has issued proposed “first-in-the-nation” cybersecurity rules that could place a heavy compliance burden on affected financial companies; Morgan Lewis submitted a comment letter...more

CFPB Releases Final Rule on Prepaid Cards - Retail Did You Know?

Dear Retail Clients and Friends, The Consumer Financial Protection Bureau (CFPB) recently released rules that impose specific requirements applicable to prepaid accounts, including prepaid cards. This edition of Morgan...more

NYDFS: “First-In-The-Nation” Cybersecurity Proposal

New “first-in-the-nation” cybersecurity rules in the pipeline for banks, insurers, and financial services companies regulated in New York could prove costly for companies, but will they improve cybersecurity?...more

CFPB Previews Anticipated Debt Collection Regulations

The long-expected CFPB summary of new rule proposals for third-party debt collectors would have major implications not only for the debt collectors themselves, but also for the banks and other financial institutions doing...more

Supreme Court Denies Certiorari Petition in Madden Case

Although it is reasonably unlikely that other circuit courts will follow the Second Circuit decision, it is uncertain whether application of the Madden case in the Second Circuit will be confined to its facts....more

FinCEN Requires Financial Institutions to Obtain Beneficial Ownership

FinCEN’s new CIP beneficial owner rules may hinder the ability of shell and nominee companies to directly access the US financial system without disclosing the natural persons who own 25% or more of the company. Pooled...more

The Conference of State Bank Supervisors Adopts Model Regulatory Framework for Virtual-Currency Businesses

Addressing regulatory concerns pertaining to consumer protection, market stability, and law enforcement, the Framework expands on the CSBS draft framework released in December 2014. The Conference of State Bank...more

AML Requirements Proposed for SEC Registered Advisers

On August 25, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of the Treasury (Treasury), published a notice of proposed rulemaking (NPRM) to impose anti-money laundering (AML) programs and...more

CFPB Issues List of Consumer Protection Concerns for New Faster Payment Systems

The Consumer Protection Principles continue the CFPB’s expansive approach. Stating that it wants to ensure that “any new payment systems are secure, transparent, accessible, and affordable to consumers” and have “robust...more

Volcker Rule: New FAQs Regarding Foreign Public Funds and Joint Venture Covered Fund Exclusions

Additional guidance issued five weeks before the July 21, 2015 conformance date. On June 12, the five federal agencies jointly responsible for implementing the Volcker Rule (the Agencies) released two new “Frequently...more

NYDFS Releases Final Rules for Licensing Virtual Currency Businesses in New York

After multiple proposals and significant industry comment, the NYDFS has released a final “BitLicense” framework that establishes a comprehensive licensing and regulatory regime for New York businesses engaged in activities...more

The CFPB and the Future of Arbitration Clauses

The CFPB has issued a report regarding mandatory consumer arbitration clauses, a sign that arbitration clauses may become passé. On March 10, the Consumer Financial Protection Bureau (CFPB), as required by section...more

OCC’s Updated Guidance on Retail Nondeposit Investment Products

The Office of the Comptroller of the Currency (OCC) recently released an updated and substantially revised section of its Comptroller’s Handbook titled “Retail Nondeposit Investment Products” (the Booklet). The Booklet...more

SEC Extends AML Relief for Broker-Dealer CIP Reliance on Advisers

The SEC’s action suggests that formal antimoney laundering program requirements for investment advisers may be on the horizon. On January 9, the staff of the U.S. Securities and Exchange Commission (SEC) issued the...more

The Fed Extends Volcker Rule Conformance for Private Funds

The Federal Reserve Board has announced that it has extended the Volcker Rule’s conformance period for compliance with the private fund provisions for investments in, and relationships with, “legacy” covered funds....more

CFPB Proposes Sweeping New Regulations for Prepaid Products

CFPB proposes to regulate a wide variety of prepaid access devices (card-based, electronic, or virtual) as equivalent to credit cards. The Consumer Financial Protection Bureau (CFPB) recently proposed extensive new...more

The Latest from Dodd-Frank: Credit Risk Retention Rule Finalized

In the latest significant rulemaking arising out of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), on October 22, six federal financial and housing agencies finalized long-awaited rules on...more

FinCEN Proposes to Expand Financial Institution Customer Due Diligence Requirements

The proposal would require financial institutions to identify beneficial owners of legal entities and codify existing customer due diligence guidance....more

OCC Issues Updated Guidance on Collective Investment Funds

The update to the Comptroller’s Handbook highlights the Office of the Comptroller of the Currency’s enhanced expectations regarding the overall risk management of collective investment fund activity and provides insight into...more

Federal Banking Agencies Finalize Supplementary Leverage Ratio Standards

The next step in the adoption of new capital standards will potentially cause the largest U.S. banking organizations to face more stringent minimum capital requirements. On April 8, the Board of Governors of the...more

Update on Economic Sanctions Triggered in Reaction to the Crisis in Ukraine

On March 17, the European Union and United States took further actions with respect to the Ukraine situation, as follows...more

3/18/2014  /  Foreign Policy , Russia , Sanctions , Ukraine

Federal Reserve Finalizes U.S. and Foreign Bank Prudential Standards

The long-awaited standards establish significant structural, liquidity, risk management, and capital requirements for the largest U.S. and foreign banks operating in the United States, including new intermediate holding...more

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