Keith R. Fisher

Keith R. Fisher

Ballard Spahr LLP

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New FAQ on Volcker Rule CEO Attestation Requirement

The five agencies that jointly issued the final Volcker Rule last December recently added to their existing list of “frequently asked questions” (FAQs) a new item addressing the attestation requirement applicable to CEOs of...more

9/22/2014 - Attestation Deadlines Banks CEOs FBOs Volcker Rule

CFPB finalizes rule to supervise larger participant international money transfer providers

The CFPB has issued a final rule that will allow it to supervise nonbank international money transfer providers that qualify as “larger participants” in the international money transfer market. Consistent with the proposed...more

9/18/2014 - CFPB EFTA Final Rules Money Transfer Nonbank Firms Regulation E

New Larger Participant Rule Enhances Supervision of Remittance Transfer Rule Requirements

The Consumer Financial Protection Bureau recently finalized a larger participant rule for nonbank international money transfer providers and left it largely unchanged from the rule as originally proposed in January. The new...more

9/17/2014 - CFPB Dodd-Frank EFTA Money Transfer Nonbank Firms Regulation E

OCC Issues Final Rule on Heightened Expectations

According to the final rule recently issued by the Office of the Comptroller of the Currency (OCC) formalizing the agency’s “heightened expectations” supervisory regime, the largest U.S. federally chartered depository...more

9/16/2014 - Banking Sector Banks Board of Directors FDIA Final Rules OCC Risk Management

Is a Uniform Debt Buying Code on Its Way?

The Uniform Law Commission (ULC), a non-partisan organization committed to drafting uniform state laws, has authorized the formation of a committee to study the need for and feasibility of state legislation to address the...more

9/4/2014 - Debt Debt Buyers OCC Uniform Law Commission

Despite FAQs and OCC Interim Examination Procedures, Little Illumination So Far for Volcker Rule Compliance

June 2014 saw the publication of some interagency FAQs on the Volcker Rule (the Rule) and interim procedures from the Office of the Comptroller of the Currency (OCC) for its examiners to use in assessing progress by national...more

8/29/2014 - Banking Sector Banks Compliance Enforcement Guidance FDIC Federal Reserve Foreign Banks OCC Volcker Rule

CFPB, AG’s, secure $92M in debt relief for servicemembers victimized by predatory lending

The CFPB, after an investigation in cooperation with 13 state attorneys general, has entered into a consent order with Colfax Capital Corporation, a California consumer lending company (Colfax), and its wholly-owned...more

8/29/2014 - CFPB Debt Debt Collection Debt-Relief Industry Military Service Members Popular Predatory Lending

House Passes Bill to Fix Privilege Waiver Problem for Nonbanks

A bill (H.R. 5062) recently passed by the House of Representatives would amend the Consumer Financial Protection Act (the CFPA), which is Title X of the Dodd-Frank legislation, to provide protection against waiver of state...more

8/28/2014 - CFPA CFPB Dodd-Frank Nonbank Firms Privilege Waivers Title X

FinCEN Proposes More Extensive Customer Due Diligence Obligations

As part of the U.S. Treasury Department’s ongoing efforts to combat all forms of illicit financial activity, from terrorist financing and sanctions evasion to more traditional financial crimes (including money laundering,...more

8/27/2014 - Covered Banking Entity Covered Financial Institutions Due Diligence FinCEN Rulemaking Process U.S. Treasury

Standard Chartered To Pay $300M To Settle AML Charges in New York

For the second time in two years, Benjamin Lawsky, the Superintendent of the New York State Department of Financial Services (DFS), has settled another matter with Standard Chartered Bank for alleged “anti-money laundering...more

8/25/2014 - Anti-Money Laundering Banks Enforcement Actions Settlement Standard Chartered Bank

FDIC Issues Guidance on Basel III Capital Conservation Buffer for Subchapter S Banks

A recent Financial Institution Letter provides guidance on the FDIC’s methodology when entertaining requests from banks or savings associations organized as Subchapter S corporations (S-corporation banks) to pay dividends to...more

8/15/2014 - Banks Basel Committee Basel III Capital Controls FDIC S-Corporation

OCC consumer protection standards in new Bulletin may influence CFPB Debt Sales Examinations of Banks

As noted in our recent Alert, the Office of the Comptroller of the Currency (OCC) has issued Bulletin 2014-37 on Consumer Debt Sales (the “Bulletin”). The Bulletin addresses the application of consumer protection requirements...more

8/7/2014 - Banks CFPB Debt OCC

Comptroller of the Currency Publishes Guidance on Debt Sales Arrangements and Agreements

The Office of the Comptroller of the Currency’s (OCC’s) new Bulletin 2014-37 on Consumer Debt Sales represents the agency’s latest guidance on this topic since providing a written statement a year ago to the Senate...more

8/7/2014

CFPB and federal banking regulators increase focus on cybersecurity

As part of their increased focus on cybersecurity, the CFPB and federal banking are taking steps to raise financial institutions’ awareness about the need for preparedness. On June 24, 2014, the Federal Financial Institutions...more

7/15/2014 - Banks CFPB Cybersecurity FFIEC SEC

Federal Bank Regulators Increase Focus on Cybersecurity

As banking regulators increase their focus on cybersecurity, they are taking steps to raise financial institutions’ awareness about the need for preparedness. On June 24, 2014, the Federal Financial Institutions Examination...more

7/14/2014 - Banks Cybersecurity FFIEC

OIG updated work plan adds focus to information security, compensation, and distribution of civil penalty funds

The most notable items added by the Office of Inspector General (OIG) to its work plan, updated as of July 7, 2014, are audits of the CFPB’s information security program, pay and compensation program, and distribution of...more

7/14/2014 - Audits CFPB Civil Penalty Fund Cybersecurity Dodd-Frank Federal Reserve OIG Popular

Supplemental Interagency Guidance on Tax Allocation Agreements

The federal bank regulators recently issued additional guidance on intercompany income tax allocation agreements between holding companies and their depository institution subsidiaries. Intended to clarify the ownership of...more

7/8/2014 - Bank Holding Company Banking Sector Banks Consolidated Tax Returns Nonbank Firms Subsidiaries Tax Allocation Agreements Tax Refunds

Additional Volcker Rule Guidance Addresses Some Low-Hanging Fruit

When the Volcker Rule was issued by the bank regulators in conjunction with the Securities and Exchange Commission and the Commodity Futures Trading Commission (collectively, the Agencies) last December (the Final Rule), it...more

7/2/2014 - Banking Sector Banks CFTC Federal Reserve Final Rules Reporting Requirements SEC Volcker Rule

Treasury Extends FATCA Compliance Date, Announces Other Amendments Affecting Foreign Banks

The Internal Revenue Service (IRS) recently announced in Notice 2014-33 that 2014 and 2015 will be transitional years from an administrative and enforcement perspective regarding the implementation of the Foreign Account Tax...more

5/13/2014 - Amended Regulation Compliance FATCA FFI IRS U.S. Treasury

Federal Reserve Extends Compliance Period under Volcker Rule for Collateralized Loan Obligations

While collateralized loan obligation vehicles (CLOs) may ultimately have to be divested by “banking entities” subject to the Volcker Rule, the Federal Reserve Board (the Board) recently extended the compliance period for...more

4/23/2014 - Banks Collateralized Loan Obligations Debt Securities Exclusions Federal Reserve Time Extensions Volcker Rule

N.Y. Banking and Insurance Superintendent Unveils Aggressive Agenda

Benjamin M. Lawsky, who heads the New York State Department of Financial Services (DFS), indicated that his agency is seriously considering more aggressive investigation and pursuit of individuals whose malfeasance has led...more

3/26/2014 - Anti-Corruption Anti-Money Laundering Banks Compliance Department of Financial Services Enforcement

Fed Seeks Public Comment on Financial Holding Company Physical Commodities Activities

An Advance Notice of Proposed Rulemaking (ANPR) issued in mid-January by the Federal Reserve Board (the Board) seeks public comment on the scope of permissible physical commodities activities. Such activities have been under...more

3/14/2014 - Bank Holding Company Dodd-Frank Energy Federal Reserve Public Comment

OCC Releases Guidelines on 'Heightened Expectations' for Large National Banks and Savings Associations

The Office of the Comptroller of the Currency (OCC) recently released proposed amendments to its Part 30 regulations, which reflect the agency's "heightened expectations" for large banks. That release, styled as an "Interim...more

2/4/2014 - Audits Banks Board of Directors Compliance Corporate Governance OCC Risk Management

CFPB issues proposal to supervise “larger participant” international money transfer providers

We had been expecting the CFPB’s next “larger participant” proposal to be a rule for the auto finance market. Instead, the CFPB issued a proposed rule yesterday that would allow it to supervise nonbank international money...more

1/24/2014 - Banks CFPB Dodd-Frank Larger Participant Money Transfer Nonbank Firms

OCC Releases Guidelines on ‘Heightened Expectations’ for Large National Banks and Savings Associations

The Office of the Comptroller of the Currency (OCC) last week released proposed amendments to its Part 30 regulations, which reflect the agency’s “heightened expectations” for large banks. That release, styled as an “Interim...more

1/23/2014 - Audits Banks Federal Savings Associations OCC Risk Management

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