The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule (the Final Rule) on August 28 that will treat certain investment advisers and exempt reporting advisers as financial...more
9/19/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Compliance ,
Compliance Dates ,
Data-Sharing ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Investment Funds ,
Patriot Act ,
Suspicious Activity Reports (SARs)
On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Treasury Department, and the Securities and Exchange Commission (SEC) proposed a joint rule (the Proposed Rule) with respect to a...more
The Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Treasury Department, has issued a proposed rule (the “Proposal”) that would subject certain investment advisers to anti-money laundering (“AML”)...more
2/19/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Investment Adviser ,
Proposed Rules ,
Recordkeeping Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
In This Issue. The Consumer Financial Protection Bureau (CFPB) reminded institutions of a new threshold for reporting Home Mortgage Disclosure Act data about open-end lines of credit; the Financial Crimes Enforcement Network...more
11/22/2021
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
HMDA ,
Investment Adviser ,
Mortgage Lenders ,
Mortgages ,
Open-Ended Lines of Credit ,
Ransomware ,
Reporting Requirements ,
Risk Alert ,
Robo-Advisors ,
Securities and Exchange Commission (SEC) ,
Threshold Requirements
In This Issue. The U.S. Securities and Exchange Commission (SEC) published a sample comment letter on climate change disclosures; the Financial Industry Regulatory Authority (FINRA) is conducting a review of brokerage firm...more
9/24/2021
/ Banking Sector ,
Broker-Dealer ,
Business E-Mail Compromise (BEC) ,
Climate Change ,
Community Development Financial Institution (CDFI) ,
Corporate Social Responsibility ,
Cybersecurity ,
Depository Institutions ,
Disclosure Requirements ,
FDIC ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
Influencers ,
Investment Adviser ,
Investment Firms ,
Investors ,
OCC ,
OTCBB ,
Policies and Procedures ,
Popular ,
Publicly-Traded Companies ,
Sanctions ,
SEC Comment Letter Process ,
Securities and Exchange Commission (SEC) ,
Social Media
In This Issue. The Consumer Financial Protection Bureau (CFPB) withdrew its proposal to delay the Debt Collection Final Rules; the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance...more
9/17/2021
/ Banking Sector ,
Banks ,
Broker-Dealer ,
Comment Period ,
Community Banks ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Debt Collectors ,
Digital Platforms ,
Due Diligence ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Services Industry ,
FinTech ,
FRB ,
Investment Adviser ,
Investment Companies ,
Investment Company Act of 1940 ,
OCC ,
Proposed Rules ,
Public Comment ,
Regulation F ,
Retail Investors ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Third-Party Risk
In This Issue. The federal bank regulators published frequently asked questions concerning the London Interbank Offered Rate transition; the Consumer Financial Protection Bureau (CFPB) confirmed an effective date for two...more
8/6/2021
/ Annual Meeting ,
Banking Sector ,
Breach of Duty ,
Broker-Dealer ,
Capital Rules ,
Comment Period ,
Comptroller ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Debtors ,
FDCPA ,
FDIC ,
Federal Reserve ,
FedNow ,
Fiduciary Duty ,
Final Rules ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
Inter-Bank Offered Rates (IBORs) ,
Investment Adviser ,
Investment Company Act of 1940 ,
Investment Firms ,
Investors ,
Libor ,
OCC ,
Proposed Rules ,
Public Comment ,
Rulemaking Process ,
Section 36(b) ,
Securities and Exchange Commission (SEC)
In This Issue. The federal bank regulatory agencies requested public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships; the Office of the Comptroller of...more
7/30/2021
/ Banking Sector ,
Climate Change ,
Comment Period ,
Cross Trading ,
Disclosure Requirements ,
FDIC ,
Fees ,
Fiduciary Duty ,
Financial Services Industry ,
Fixed Income Investments ,
Investment Adviser ,
OCC ,
Policies and Procedures ,
Proposed Guidance ,
Public Comment ,
Registered Investment Advisors ,
Regulatory Agencies ,
Risk Alert ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Third-Party Risk
On January 30, 2020, the Board of Governors of the Federal Reserve System (Federal Reserve) issued a final rule (Rule) that revises the Federal Reserve’s regulations related to determinations of whether a first company (an...more
2/5/2020
/ Bank Holding Company Act ,
Banks ,
Board of Directors ,
Board of Governors ,
CBCA ,
CEOs ,
Controlling Influence Test ,
Controlling Stockholders ,
Divestiture ,
Equity Investors ,
Established Business Relationship ,
Federal Reserve ,
Fiduciary Exception ,
Final Rules ,
Financial Statements ,
GAAP ,
HOLA ,
Investment Adviser ,
Investment Companies ,
Investment Funds ,
Investors ,
Management Agreements ,
Non-Controlling Interests ,
Private Equity ,
Proxy Solicitations ,
Publicly-Traded Companies ,
Senior Managers ,
Voting Securities
The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more
8/31/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Broker-Dealer ,
BSA/AML ,
CIP ,
Comment Period ,
Cross-Border Transactions ,
Currency Transaction Reports (CTR) ,
Financial Institutions ,
FinCEN ,
Information Sharing ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Money Laundering ,
Patriot Act ,
Proposed Regulation ,
Recordkeeping Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
Training Requirements
The Volcker rule generally prohibits banking entities from engaging in proprietary trading and from sponsoring and/or investing in certain types of “covered” investment funds. The implementing regulation that the Agencies...more
7/20/2015
/ Business Development Companies ,
CFTC ,
Covered Banking Entity ,
FDIC ,
Federal Reserve ,
Investment Adviser ,
Investment Companies ,
New Guidance ,
OCC ,
Proprietary Trading ,
Securities and Exchange Commission (SEC) ,
Seed Financing ,
Volcker Rule
Regulatory Developments -
CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more
6/18/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Brokers ,
CFTC ,
Civil Monetary Penalty ,
Community Banks ,
Enforcement ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
No-Action Letters ,
No-Action Relief ,
Reporting Requirements ,
Swap Dealers ,
Swaps
Regulatory Developments:
SEC Chair Highlights Recent Accomplishments -
In a June 4, 2015 speech, SEC Chair Mary Jo White highlighted recent activities of the SEC and identified work to be done in the near future....more
6/11/2015
/ Avon ,
Banks ,
Broker-Dealer ,
Comptroller ,
Dodd-Frank ,
EDGAR ,
FDIC ,
Federal Reserve ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Investment Adviser ,
JOBS Act ,
Market Manipulation ,
National Bank Act ,
Securities and Exchange Commission (SEC)