Charles Horn

Charles Horn

Morgan Lewis

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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

7/17/2015 - CFPB CID Data Privacy Data Protection Disclosure Requirements Dodd-Frank EFTA Electronic Payment Transactions Enforcement Authority Fee Disclosure Fraud MasterCard NACHA Payment Systems Regulation E Regulation Z Terms and Conditions Transparency Truth in Lending Act UDAAP Visa Inc

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

6/16/2015 - Covered Financial Institutions Covered Funds Exclusions Financial Institutions Investment Funds Public Funds Volcker Rule

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

6/11/2015 - Bitcoins BitLicense Department of Financial Services Licensing Rules Virtual Currency

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

3/13/2015 - Arbitration Arbitration Agreements CFPB Dodd-Frank Mandatory Arbitration Clauses

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

3/2/2015 - Banking Sector Banks Guidance Update Industry Examinations OCC

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

1/19/2015 - Anti-Money Laundering Bank Secrecy Act FinCEN Investment Adviser No-Action Relief NOPR Reporting Requirements SEC SIFMA U.S. Treasury

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

12/22/2014 - Banks Compliance Dodd-Frank Federal Reserve Hedge Funds Private Equity Funds Volcker Rule

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

12/10/2014 - CFPB Prepaid Payment Products Proposed Regulation Public Comment Rulemaking Process

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

11/5/2014 - Compliance Dodd-Frank Risk Retention Securities Exchange Act

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

8/6/2014 - Anti-Money Laundering Bank Secrecy Act Banks Compliance Due Diligence FCMs FinCEN SEC

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

6/9/2014 - Investment Funds OCC Risk Management

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

4/11/2014 - Banks FDIC Federal Reserve Financial Regulatory Reform Leverage Capital Ratio OCC

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

3/3/2014 - Banks Dodd-Frank Federal Reserve Foreign Banks Prudential Standards

OCC Seeks to Formalize Risk Governance Expectations of Large Banks

The proposed guidelines demonstrate the Office of the Comptroller of the Currency’s continued emphasis on strong risk management for large banks. ...more

1/28/2014 - Banks FDIA FDIC Foreign Banks OCC Risk Management

Federal Reserve Revisits FHC Commodities and Merchant Banking Activities

New advanced notice of proposed rulemaking requests public comments on physical commodities activities and merchant banking investments of financial holding companies. The Board of Governors of the Federal Reserve...more

1/20/2014 - Bank Holding Company Act Commodities Federal Reserve Financial Holding Company Financial Regulatory Reform

Community Bank TruPS CDOs Exempted from the Volcker Rule

Interim final rule exempts collateralized debt obligation vehicles that hold qualifying community bank trust preferred securities from the private fund sponsorship and investment prohibitions....more

1/17/2014 - Banks Collateralized Debt Obligations Community Banks Compliance Dodd-Frank Proprietary Trading Trust Preferred Securities Volcker Rule

A Review of, and Insights into, the Volcker Rule Regulations

Executive Summary: ..The final regulations (Regulations) adopted by the five federal financial regulatory agencies (Agencies) on December 10, 2013 to implement the proprietary trading and private fund prohibitions of...more

1/8/2014 - Banks Compliance FDIC Federal Reserve OCC Proprietary Trading Reporting Requirements Underwriting Volcker Rule

Federal Reserve Board Proposes Stricter Bank Liquidity Rules

Proposed rules include a shorter transition period, a narrower definition of what qualifies as “high quality liquid assets,” and a more stringent liquidity stress-testing methodology than the framework issued by the Basel...more

10/30/2013 - Banks Basel Committee Basel III Dodd-Frank Federal Reserve Liquidity Coverage Ratio

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