COVID-19 and the resulting economic downturn are expected to strain the U.S. banking system at a time when banks are grappling with how to modernize their products and services and keep pace with technological innovation....more
The office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) on June 3, 2020, focusing on digital banking activities. Typically such ANPRs are a precursor to new federal...more
1. Q. The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) implements the disbursement of $1,200 payments of COVID-19 stimulus funds to millions of Americans. How will the current payment system address the...more
The COVID-19 pandemic presents extraordinary and unique challenges for financial institutions. Banks provide critical financial services to the public and are an integral part of the financial life of most Americans. Unlike...more
Innovation and rapid change are permeating financial services. But amidst those trends, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) recently took action aimed at maintaining the status quo....more
What is Open Banking?
Open banking is a collaborative model in which banks and other similar regulated financial institutions are required to share their customers’ financial data with third parties upon the request of...more
Recently, an American bank entered into a deferred prosecution agreement requiring it to pay over US$610 million in penalties. The plea agreement was based on “impos[ing] hard caps on the number of transactions subject to AML...more
A serious regulatory issue can derail a bank merger or acquisition. Sometimes a bank will begin a transaction with a known, pre-existing regulatory issue, and other times an unanticipated regulatory issue develops during the...more
Some bankers view the rapid rise of “fintech” as an existential threat to traditional banks, especially community banks. But while fintech surely is changing financial services, it is also creating new opportunities for...more
On October 25, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory (the “Advisory”) explaining the obligations a “financial institution” might have under the Bank Secrecy Act (“BSA”) regarding...more
Since the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) government regulation has been pushing the mortgage banking industry toward homogenized residential mortgage loans...more