Keith R. Fisher

Keith R. Fisher

Ballard Spahr LLP

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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

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

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

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

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

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

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

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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