This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer due diligence rule of the Federal Financial Institutions Examination Council. The Board of Governors of the Federal Reserve System (“FRB”) published proposed amendments to Regulation J to conform with previous changes to Regulation CC. Also, the American Bar Association’s House of Delegates approved a model statute drafted by the Uniform Law Commission regarding virtual currency businesses. Further, the Bureau of Consumer Financial Protection (“CFPB”), the Federal Trade Commission (“FTC”), and the Office of the Comptroller of the Currency (“OCC”) entered into consent orders and took other enforcement action relating to bank deposits and payment system practices.
Originally published in The Business Lawyer; Vol. 74, Spring 2019.
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