Major Developments
U.S. Department of the Treasury
Financial Crimes Enforcement Network
Office of Foreign Assets Control
Al-Huda Bank Severed from US Financial System
January 29, 2024
The U.S. Department of the Treasury issued a finding and notice of proposed rulemaking (NPRM) that identifies an Iraqi bank that serves as a conduit for terrorist financing, as a foreign financial institution of primary money laundering concern. Along with its finding, the Financial Crimes Enforcement Network (FinCEN) proposed a rule that would sever the bank from the U.S. financial system by prohibiting domestic financial institutions and agencies from opening or maintaining a correspondent account for or on behalf of Al-Huda Bank. In addition, the Office of Foreign Assets Control (OFAC) is imposing sanctions on the bank's owner.
Office of the Comptroller of the Currency
OCC Requests Comments on Proposed Rulemaking and Policy Statement on Bank Mergers
January 29, 2024
The Office of the Comptroller of the Currency seeks to update its business combination regulations to strike its long-standing expedited decision-making process for certain well managed and well capitalized banks engaged in non-controversial mergers and reorganizations. The Acting Comptroller announced the possible new regulatory burden in a speech at the University of Michigan's Ross School of Business.
Federal Agencies
U.S. Department of the Treasury
Economy Statement by Eric Van Nostrand, performing duties of Assistant Secretary for Economic Policy for the Treasury Borrowing Advisory Committee
January 29, 2024
Acting Assistant Secretary for Economic Policy Eric Van Nostrand issued the economy statement for the Treasury Borrowing Advisory Committee.
The United States and United Kingdom Target Iranian Transnational Assassinations Network
January 29, 2024
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) and the United Kingdom are taking joint action against a network of individuals that targeted Iranian dissidents and opposition activists for assassination at the direction of the Iranian regime.
Consumer Financial Protection Bureau
Blog: The CFPB's enforcement work in 2023 and what lies ahead
January 29, 2024
The Consumer Financial Protection Bureau published a blog post entitled, "The CFPB's enforcement work in 2023 and what lies ahead."
Financial Crimes Enforcement Network
FinCEN Seeks Comments on the Information to be Collected from Authorized Recipients Requesting Beneficial Ownership Information
January 29, 2024
The Financial Crimes Enforcement Network (FinCEN) is seeking comments on the information to be collected from certain authorized recipients requesting access to beneficial ownership information, consistent with the requirements of the final Access and Safeguards rule.
Federal Housing Finance Agency
Blog: The Enterprises' Multifamily Support in Areas of Concentrated Poverty
January 29, 2024
The Federal Housing Finance Agency published a blog post entitled, "The Enterprises' Multifamily Support in Areas of Concentrated Poverty."
Bank Policy Institute
Blog: Deposit and Interest Rate Risk: Some Simple But Surprising Results
January 29, 2024
The Bank Policy Institute published a blog post entitled, "Deposit and Interest Rate Risk: Some Simple But Surprising Results."
International
European Banking Authority
The EBA seeks inputs from credit institutions on the classification methodologies for exposures to ESG risks
January 29, 2024
The European Banking Authority launched an industry survey to receive input from credit institutions on their methodologies to classify exposures to environmental, social and governance (ESG) risks, as well as on the accessibility and availability of ESG data for this purpose.
Bank of England
Speech: Non-bank risks, financial stability and the role of private credit
January 29, 2024
The Bank of England's Director of Financial Stability, Strategy and Risk Lee Foulger gave a speech entitled, "Non-bank risks, financial stability and the role of private credit," at the Deal Catalyst/AFME Direct Lending and Middle Market Finance Conference.
Administration Changes
Vacancies
Office of the Comptroller of the Currency
- Comptroller – Vacant (Michael Hsu serves as Acting Comptroller)
Appointments/Confirmation Hearings
U.S. Department of the Treasury – Janet Yellen (effective January 26, 2021)
Federal Reserve Board – Jerome H. Powell (effective May 23, 2022)
- Vice Chair Phillip N Jefferson (sworn in September 13, 2023)
- Vice Chair for Supervision Michael Barr (sworn in July 19, 2022)
- Governor Michelle W. Bowman (sworn in November 26, 2018)
- Governor Christopher J. Waller (sworn in December 18, 2020)
- Governor Lisa D. Cook (sworn in September 13, 2022)
- Governor Adriana D. Kugler (sworn in September 13, 2023)
Federal Reserve Bank of New York – John C. Williams (effective June 18, 2018)
Federal Reserve Bank of Boston – Susan M. Collins (effective July 1, 2022)
Federal Deposit Insurance Corporation – Martin Gruenberg (effective January 5, 2023)
- Vice Chairman Travis Hill (sworn in January 5, 2023)
- Director Jonathan McKernan (sworn in January 5, 2023)
- Director Michael Hsu (Acting Comptroller of the Currency)
- Director Rohit Chopra (Director of Consumer Financial Protection Bureau)
Office of the Comptroller of the Currency – Michael Hsu (acting Comptroller, effective May 10, 2021)
Securities and Exchange Commission – Gary Gensler (effective April 17, 2021)
Commodity Futures Trading Commission – Rostin Behnam (effective December 17, 2021)
Consumer Financial Protection Bureau – Rohit Chopra (effective October 12, 2021)
National Credit Union Administration – Todd M. Harper (effective January 20, 2021)
Small Business Administration – Isabella Casillas Guzman (effective March 16, 2021)
U.S. Department of Housing and Urban Development – Marcia Fudge (effective March 10, 2021)
Federal Housing Finance Agency – Sandra L. Thompson (effective June 22, 2022)
U.S. Department of Education – Dr. Miguel Cardona (effective March 2, 2021)
Financial Crimes Enforcement Network – Andrea Gacki (effective July 13, 2023)
PH Client Alerts
Click here to read more from our Coronavirus series.
Legislation/Legislative Updates
Click here to view the full text of the Coronavirus Aid, Relief and Economic Security Act (the "CARES Act"), Enacted March 27, 2020.
Click here to view the full text of the Paycheck Protection Program Increase Act of 2020, Enacted April 24, 2020.
Click here to view the full text of the Paycheck Protection Program Flexibility Act of 2020, Enacted June 5, 2020.
Click here to view the full text of the Consolidated Appropriations Act, 2021, Enacted December 27, 2020.
Click here to view the full text of the American Rescue Plan of 2021, Enacted March 11, 2021.
Click here to view the full text of the PPP Extension Act of 2021, Enacted March 30, 2021.
Click here to view a running list of proposed legislation from the Senate Committee on Banking, Housing, and Urban Affairs, Senate Committee on Small Business and Entrepreneurship, House Committee on Financial Services, and House Committee on Small Business.
