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New York State Cybersecurity Regulations: First milestone in sight, what is next on the horizon?

The New York State Department of Financial Services (“NYDFS”) enacted final cybersecurity regulations (“Regulations”) for NYDFS regulated entities that went into effect on March 1, 2017. The first deadline for compliance...more

The OCC Takes Initiative on Seeking Public Comment for Changes to the Volcker Rule

The Office of the Comptroller of the Currency (OCC), which regulates national banks and, as such, is responsible for administering the Volcker Rule with respect to the largest banking entities in the United States, has...more

US Banking Agencies Provide Temporary Relief Under the Volcker Rule to Foreign Banks With Respect to Certain Foreign Private...

The US federal banking agencies with responsibility for enforcing the Volcker Rule have issued temporary one year no-action relief with respect to certain private non-US investment funds that are not “covered funds” for...more

CHOICE Act 2.0 Passes the House: What Is the ‘CHOICE’?

On June 8, 2017, the House of Representatives passed an amended version of H.R. 10, the Financial CHOICE Act of 2017, or CHOICE Act 2.0, which scales back or eliminates many of the post-crisis financial reforms that were...more

Financial Regulatory Developments Focus - March 2017

In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more

Financial Regulatory Developments Focus - February 2017

In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more

Financial Regulatory Developments Focus - January 2017

In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more

Financial Regulatory Developments Focus - December 2016

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Implications for Non-EU Banking Groups of the EU’s New Intermediate Holding Company Proposals

The European Commission has published draft legislative proposals which would require large non-EU banking firms with EU operations to establish an intermediate holding company in the EU. The proposed rules are similar to US...more

Financial Regulatory Developments Focus - October 2016

Bank Prudential Regulation & Regulatory Capital - US Board of Governors of the Federal Reserve System Releases Proposed Rule to Modify Capital Plan and Stress Testing Rules - On September 26, 2016, the US Board of...more

Financial Regulatory Developments Focus - September 2016

In this newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset managers and...more

NYS Department of Financial Services Outlines Requirements for Transaction Monitoring and Filtering Programs of NY State-Licensed...

On June 30, 2016, the New York State Department of Financial Services (“NYSDFS”) adopted a final regulation outlining the attributes of a risk-based transaction monitoring and filtering program that certain New York...more

Second Circuit Holds a National Bank’s Citizenship Is Determined Exclusively by Location of Main Office, Not Principal Place of...

For purposes of assessing the existence of federal subject matter jurisdiction based on diversity of citizenship, national banking associations—i.e., corporate entities chartered not by any State, but by the Office of the...more

Latest Developments in US Privacy and Technology Law

This update provides a snapshot of the Senate’s vote on expansion of the FBI’s National Security Letter authority and the House’s upcoming vote on the Financial Services and General Government appropriations bill as it...more

Financial Regulatory Developments Focus - June 2016 #2

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

FinCEN Issues Final Beneficial Owner Identification Rules

In May 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network issued final rules regarding beneficial owner identification obligations for legal entity customers (the “Rule”). Under the Rule, covered...more

Financial Regulatory Developments Focus - June 2016

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - May 2016 #3

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - May 2016 #2

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - May 2016

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - April 2016 #3

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - April 2016 #2

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - April 2016

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

Financial Regulatory Developments Focus - March 2016 #4

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

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