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Orrick's Financial Industry Week In Review

Financial Industry Developments - Prohibition on Dealing or Investing in Industrial or Commercial Metals - On January 3, 2017, the Office of the Comptroller of the Currency (the "OCC") finalized a rule that...more

New York Department of Financial Services Revises Proposed Cybersecurity Rule

The New York Department of Financial Services (NYDFS) recently issued a revised proposed regulation seeking to add its own mandate of cybersecurity requirements to those already in existence for banks, insurance companies and...more

How Distributed Ledger Technology Might Grow in the Insurance Industry

On Jan. 5, 2017, the Department of Treasury Federal Insurance Office held its first committee meeting of the new year. Several topics were addressed, including the use of blockchain/distributed ledger technology (“DLT”) in...more

Real Property & Title Insurance Update: Week Ending January 6, 2017

REAL PROPERTY UPDATE - Foreclosure – Involuntary Dismissal: although lender’s witnesses failed to explain lender’s loan payment history statement, the statement reflected the principal amount due and had been admitted...more

New York State Revises “First-In-Nation” Cybersecurity Rules

The New York Department of Financial Services (“DFS”) recently issued a revised version of the cybersecurity rules that it first announced in the fall of last year. The rules apply to a wide range of insurance, banking, and...more

Your Daily Dose of Financial News

By volume, December wasn’t an incredible month for US jobs. But the report did help cap a year that saw average hourly earnings rise 2.9%—the best since 2009 and a “turning point for the overall economy,” according to one...more

Although Delayed, New York's Aggressive Cybersecurity Law Expected to Affect Financial Services and Insurance Firms

The regulatory environment for cybersecurity is rapidly changing, and state legislatures are not waiting for Congress to act. On December 28, 2016, the New York State Department of Financial Services ("NYDFS") revised a...more

Actualite Juridique - Decembre 2016

Assurance - Résiliation d'un contrat d'assurance emprunteur pour cause d'aggravation du risque - Le Décret n°2016-1559 du 18 novembre 2016 relatif aux conditions de résiliation d'un contrat d'assurance emprunteur...more

New York Department of Financial Services Revises Cybersecurity Proposal: Greater Flexibility and Delayed Compliance Deadlines

As we previously reported, in December 2016 the New York Department of Financial Services (the “DFS”) announced that it was revising its proposed regulation that would require banks, insurance companies and other financial...more

Dodd-Frank in a Trump Administration

During the recent campaign, President-elect Donald Trump pledged to repeal the Dodd-Frank Act (DFA) if elected, criticizing the regulatory burdens it imposed and contending that it discouraged lending by banks and impaired...more

SEC Watchdog to Watch Watchdog

The SEC’s Office of Compliance Inspections and Examinations (OCIE) has established a dedicated team charged specifically with inspecting FINRA and other FINRA-related work. This follows through on the SEC’s...more

FINRA Seeks Clean Sweep of Abusive Cross-Selling Practices

In late October, the Financial Industry Regulatory Authority (FINRA) announced a sweep examination of broker-dealers targeting cross-selling programs similar to those that recently resulted in Wells Fargo’s payment of an $185...more

New York State Department of Financial Services Issues Updated Proposed Cybersecurity Regulation

The New York State Department of Financial Services (“DFS”) has updated its proposed regulation requiring banks, insurance companies, and other financial services institutions regulated by DFS to establish and maintain a...more

FINRA Fines Firms For Not Supervising L-Share Annuity Sales

For two years FINRA has made sales and marketing of L-Share variable annuities (VAs) a regulatory and examination priority. Not surprisingly, FINRA in November announced settled actions against eight broker-dealers, alleging...more

New York Department of Financial Services Cybersecurity Rules Revised and Delayed

The New York Department of Financial Services (NYDFS) just issued major revisions to the cybersecurity regulations for financial institutions that were due to come into effect on January 1, 2017. To allow covered institutions...more

New York Department of Financial Services Delays Compliance Deadline for Cybersecurity Regulations

On October 25, the Privacy Law Report featured a blog post on new cybersecurity regulations being implemented by the New York Department of Financial Services (“DFS”). Those regulations impose a number of requirements on...more

NYDFS Revises Cybersecurity Regulation, Extends Effective Date to March 1, 2017

The New York Department of Financial Services (NYDFS) announced today a revised regulation that will require all institutions subject to NYDFS supervision to establish and maintain a cybersecurity program meeting "certain...more

PRIIPs and KIDs – how are they relevant to funds?

The aim of the PRIIPs Regulation is to help retail investors to better understand and compare the key features, risks, rewards and costs of different retail products, by requiring that retail investors are provided with...more

Real Property & Title Insurance Update: Weeks Ending December 2 & 9, 2016

REAL PROPERTY UPDATE - Deficiency/Subject Matter Jurisdiction: approving the 3d DCA’s opinion that an assignee of a foreclosure judgment can maintain a separate action for deficiency under Florida Statutes, Section...more

Real Property & Title Insurance Update: Weeks Ending November 18 & 25, 2016

REAL PROPERTY UPDATE - Settlement/Waiver: borrowers permitted to raise affirmative defenses and counterclaims against lender where subject Loan Modification Agreement failed to include waiver of claims, affirmative...more

DFS Cyber Regulation: Changing the Rules – An Interview with Bay Dynamics’ Steven Grossman

As part of Patterson Belknap’s continuing focus on the New York Department of Financial Services (DFS) proposed cybersecurity regulation, we sat down with Steven Grossman, VP Strategy & Enablement at Bay Dynamics, a cyber...more

What Might Be the Future of the Dodd -Frank Act’s Insurance and Reinsurance- Related Provisions in a Trump Administration?

During the recent election campaign, President-elect Donald Trump pledged to repeal the Dodd-Frank Act if elected, criticizing the regulatory burdens it imposed on different portions of the financial services sector and...more

NY DFS Proposes New Regulation for Life and Annuity Non-Guaranteed Elements

On November 17, the New York Department of Financial Services (DFS) issued a press release announcing its proposal of new Insurance Regulation 210 - Life Insurance and Annuity Non-Guaranteed Elements. Non-guaranteed elements...more

Revised Uniform Unclaimed Property Act Finalized for State Enactment—Legislative Drafting Notes and Interpretative Comments Added ...

The fourth iteration of a uniform unclaimed property act—entitled the Revised Uniform Unclaimed Property Act (RUUPA or Act)—has been finalized by the Uniform Law Commission for state enactment. The new Prefatory Note,...more

Real Property & Title Insurance Update: Weeks Ending November 4 & 11, 2016

REAL PROPERTY UPDATE - Foreclosure/Constitutional Challenge: record title owner’s argument that Florida Statutes section 702.035, governing “Legal notice concerning foreclosure proceedings,” is an unconstitutional...more

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