Keith R. Fisher

Keith R. Fisher

Ballard Spahr LLP

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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

Volcker Rule Agencies Issue Interim Final Rule Exempting TruPS-backed CDOs

Last week, the five agencies that jointly issued the final regulation implementing the Volcker Rule (the Final Rule) in December issued an interim final rule (the Interim Rule) that exempts collateralized debt obligations...more

1/23/2014 - American Bankers Association Collateralized Debt Obligations Dodd-Frank Final Rules Financial Regulatory Reform Trust Preferred Securities Volcker Rule

Controversy over the Volcker Rule and Trust-Preferred CDOs

The banking industry’s recent challenge to the newly promulgated Volcker Rule focuses on collateralized debt obligations backed by trust-preferred securities (TruPS CDOs). Even though TruPS CDOs do not represent the kind of...more

1/6/2014 - Bank Holding Company Act Banks Collateralized Debt Obligations Community Banks Trust Preferred Securities Volcker Rule

Volcker Rule Promises To Be Godzilla of Bank Regulation

It took almost 3½ years before it finally hatched. And it was big—very big—enormous, in fact. No, it’s not Godzilla. It’s the Volcker Rule. More than two years after the Notice of Proposed Rulemaking, a final rule...more

12/30/2013 - Bank Holding Company Act Banks Dodd-Frank FDIC Federal Reserve OCC Proprietary Trading SEC Volcker Rule

Regulators Revise Interagency Q&A on the Community Reinvestment Act

Recently, the federal banking agencies—the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation—issued revisions to Interagency...more

12/20/2013 - Community Development Entities CRA FDIC Federal Reserve Insured Depository Institutions Lenders OCC

Prudential Regulators Clarify Supervisory Approach Relative to CFPB Mortgage Regulation

The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the National Credit Union Administration, and the Office of the Comptroller of the Currency (the “Prudential Regulators”) have...more

12/20/2013 - Ability-to-Repay CFPB CRA FDIC Federal Reserve Mortgages NCUA OCC Qualified Mortgage Rule

OCC Adds Substantial New Risk Management Burdens for Third-Party Relationships

The Office of the Comptroller of the Currency (OCC) recently issued a new Bulletin 2013-29 containing substantially more onerous risk management guidance for third-party business relationships (3PRs) of national banks and...more

11/26/2013 - Banks Compliance Federal Savings Associations OCC Risk Management Third-Party Relationships

OCC Announces Standards for Third-Party Consultants

The Office of the Comptroller of the Currency (OCC) recently issued guidance on what it looks for when requiring national banks and federal thrifts in enforcement orders to engage third-party consultants (3PCs). Bulletin...more

11/26/2013 - Compliance Consultants Consultation Enforcement OCC Third-Party Liability

CFPB issues examination procedures for remittance transfers

The Bureau has updated its examination manual with procedures to be followed when examining institutions that make remittance transfers for consumers. A remittance transfer is a wire transfer sent by a consumer in the United...more

10/23/2013 - CFPB Dodd-Frank Electronic Fund Transfer Act Federal Reserve Fraudulent Wire Transfers Regulation E Remittance Transfer Rule UDAAP

FDIC Clarifies Position on Bank Payment Processing for Payday Lenders and High-Risk Merchants

Last week, the FDIC issued the latest in a series of Financial Institutions Letters dating back to 2008 on the subject of banks managing third-party risk. This most recent FIL deals with payment processing for third-party...more

10/3/2013 - Banks FDIC Payday Loans

CFPB issues interim final rule on temporary C&Ds

The CFPB has issued an interim final rule with a request for public comment on its new rules of practice for the issuance of temporary cease-and-desist orders (“Temporary C&Ds”). The Bureau is authorized to issue Temporary...more

9/30/2013 - Cease and Desist CFPB FDIA

CFPB joins other federal regulators in announcing GLBA privacy exemption

On September 24, 2013, the CFPB joined the CFTC, the SEC, the FTC, the NCUA, and the prudential bank regulatory agencies (the Federal Reserve, the OCC, and the FDIC) in the issuance of an Interagency Guidance on Privacy Laws...more

9/26/2013 - CFPB Elder Abuse Exemptions GLBA Privacy Gramm-Leach-Blilely Act

Much to do about nothing? CFPB guidelines, servicemembers and payday lending

Amid fanfare about its commitment to the protection of the military, the CFPB has released new guidelines to assist its examiners regarding payday and title loans to military servicemembers and their dependents. “Protecting...more

9/23/2013 - CFPB Military Lending Act Payday Loans Richard Cordray

The District Court’s ruling in State National Bank of Big Spring v. Lew

When the State National Bank of Big Spring case challenging the constitutionality of several titles of the Dodd-Frank Wall Street Reform & Consumer Protection Act (“Dodd-Frank”) was originally filed in June 2012, I...more

8/7/2013 - CFPB Dodd-Frank FSOC Mortgages Motion to Dismiss Orderly Liquidation Authority Standing

FinCEN Provides Modest Reporting Relief for Banks Using Armored Car Services

FinCEN has issued a new ruling that will provide some relief from certain transaction reporting requirements for banks and other financial institutions using armored car services (ACS)....more

7/31/2013 - ACS Banks FinCEN

Federal Banking Agencies Encourage Student Loan Forbearance

Federal bank regulators are recognizing the plight of student loan borrowers who are unemployed or underemployed and may not be able to begin repaying their private student loan debt shortly after leaving school....more

7/31/2013 - Banks Forbearance Agreements GAAP Student Loans Students

Despite Controversy, Implementation of U.S. Basel III Capital Regime Moves Forward

In June 2012, the Board of Governors of the Federal Reserve System (the “Board”), the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) issued proposed regulations that...more

7/26/2013 - Banks Basel III Dodd-Frank FDIC OCC Proposed Regulation

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