On May 13, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed rules (CIP Rules) that would impose customer identification...more
5/21/2024
/ AML/CFT ,
Comment Period ,
Compliance ,
Customer Identification Program (CIP) ,
Customer Information ,
FinCEN ,
Investment Adviser ,
Popular ,
Proposed Rules ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more
2/26/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Comment Period ,
Compliance ,
Examination Priorities ,
Exemptions ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Information Sharing ,
Investment Adviser ,
NPRM ,
Popular ,
Proposed Rules ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
In an effort it describes as intended to help “level the playing field” between banks and nonbank consumer financial service providers that are sometimes characterized as “Big Tech”, the Consumer Financial Protection Bureau...more
Representations and Warranties Insurance (RWI) has increasingly become a tool employed by both Buyers and Sellers to shift away from the traditional indemnification model of escrows or other mechanisms that could tie up...more
8/2/2023
/ Acquisitions ,
Commercial Insurance Policies ,
Corporate Practice of Medicine ,
Cybersecurity ,
Medical Malpractice ,
Mergers ,
Patient Privacy Rights ,
Policy Terms ,
Professional Liability ,
Representations and Warranties ,
Risk Assessment ,
Terms and Conditions ,
Underwriting
Here is the latest regarding the former Silicon Valley Bank of Santa Clara, California (“SVB”) and Signature Bank of New York, NY (“SB”) as of Monday, March 13, 2023 according to the FDIC and other regulators. We expect to...more
3/14/2023
/ Banks ,
Corporate Counsel ,
Deposit Accounts ,
Deposit Insurance ,
FDIC ,
Financial Contracts ,
HSBC ,
Insolvency ,
OCC ,
Receivership ,
Silicon Valley ,
Technology Sector ,
UK
Here is the latest regarding Silicon Valley Bank (“SVB”) and Signature Bank as of Sunday, March 12th according to the FDIC. We expect to learn more by COB Monday, March 13th...more
Consumer debt collectors may not be permitted to charge consumers “convenience fees” for card payments, which the Consumer Financial Protection Board (the “CFPB”) calls “pay-to-pay” fees, unless the underlying loan agreement...more
8/19/2022
/ Advisory Opinions ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Convenience Fees ,
Debt Collection ,
Debt Collectors ,
Enforcement ,
Exclusions ,
FDCPA ,
Fees ,
Loan Agreements ,
Statutory Requirements ,
Third-Party Service Provider ,
UDAAP
On July 31, 2018, the OCC announced that it had finalized parameters for its new limited-purpose financial technology national bank charter and is ready to begin taking applications. This release follows several years of...more
The May 25, 2018, compliance effective date of the EU’s General Data Protection Regulation (GDPR) is just weeks away, and many U.S.-based companies have at least by now taken stock of their EU customer base and operations,...more
In this the new era of banking, our clients are continually looking for ways to enhance efficiency and effectiveness at all levels of their organizations. This line of thinking has led to the revolution of the bank branch and...more
Bryan Cave colleagues Ken Achenbach and Sean Christy join Jonathan and me on this episode of The Bank Account to examine the ability of banks to gain efficiency through shared services. Throughout the business environment,...more
9/8/2017
/ Automated Systems ,
Automation Systems ,
Bank Service Providers ,
Banking Sector ,
Banks ,
Consumer Financial Products ,
Financial Services Industry ,
FinTech ,
Innovative Technology ,
Outsourcing ,
Technology
Host Jonathan Hightower is joined by Ken Achenbach to discuss this week's proposed guidance from the Federal Reserve on the effectiveness of bank boards. In addition, at the outset of the episode Jonathan and Ken reviewed...more
9/5/2017
/ Banking Sector ,
Banks ,
Board of Directors ,
Community Banks ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Governance ,
Disclosure Requirements ,
FDIC ,
Federal Bank Regulatory Agencies ,
Federal Reserve ,
governance ,
Liquidity ,
Liquidity Risk Management Rule ,
Loans ,
Overdraft Fees ,
Risk Management ,
Risk Mitigation
It can be a challenge, when economic times are relatively good, to take time away from thinking about new opportunities to discuss topics like D&O insurance. Even though I am biased, I’ll admit that, in those times,...more
Bryan Cave’s Ken Achenbach joins hosts Jonathan Hightower and Rob Klingler to discuss the data-driven marketing of credit products by financial services companies....more
Ken Achenbach and Crystal Homa, attorneys in Bryan Cave's Financial Services Corporate & Regulatory team, join hosts Jonathan Hightower and Rob Klingler to discuss the current proposed legislative changes for banks chartered...more
Jonathan and Rob are joined by Ken Achenbach today to discuss the OCC's announcement from December 2nd that opened the doors for special purpose national bank charters for fintech companies....more
5/8/2017
On today's episode Jonathan Hightower and Ken Achenbach discuss the CFPB's recent data proposal and what it means for banks....more