BuckleySandler LLP

1250 24th Street, NW Suite 700
Washington, D.C. 20037, United States

Contact: Ezra Crawford

  • 202•349•8000
  • 202•349•8080

Prudential Regulators Finalize Liquidity Coverage Ratio Rule

On September 3, the OCC, the FDIC, and the Federal Reserve Board released a final rule establishing a minimum liquidity requirement for large and internationally active banking organizations. The rule will require banking…more
| Finance & Banking, International Law & Trade

Prudential Regulators Seek Comments On Proposed CRA Questions And Answers

On September 8, the OCC, the FDIC, and the Federal Reserve Board released proposed revisions to the Interagency Questions and Answers Regarding Community Reinvestment. Specifically, the agencies propose to revise three questions…more
| Finance & Banking

Prudential Regulators Finalize Supplementary Leverage Ratio Rule

On September 3, the OCC, the FDIC, and the Federal Reserve Board released a final rule that modifies the definition of the denominator of the supplementary leverage ratio in a manner consistent with recent changes agreed to by…more
| Finance & Banking

DOJ Announces Associate Attorney General’s Departure

On September 3, the DOJ announced that Associate Attorney General Tony West will depart the agency on September 15, 2014. The announcement came a year after Mr. West was confirmed for the position, though he held the position in…more
| Criminal Law

FinCEN Offers Red Flags Guidance On Human Trafficking And Smuggling

On September 11, in FIN-2014-A008, FinCEN advised financial institutions on how to detect and report suspicious financial activity that may be related to human smuggling and/or trafficking. The advisory describes the differences…more
| Finance & Banking

OFAC Fines Commodity Trading Advisor For Apparent Sanctions Violations

On September 9, OFAC released an enforcement action against a CFTC-registered Introducing Broker and Commodity Trading Advisor that operates an electronic trading platform that allows customers to automatically place currency…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Securities Law

Fannie Mae Issues Fact Sheet on Prior Derogatory Credit Event Policies

On September 8, Fannie Mae published a fact sheet about borrower eligibility after a derogatory credit event. The fact sheet reviews Fannie Mae’s recently updated policy related to the minimum waiting periods following a…more
| Bankruptcy, Finance & Banking, Real Estate - Residential

Fannie Mae Authorizes Servicers To Waive Deficiency Judgment Rights, Announces Other Servicing Policy Updates

On September 8, Fannie Mae advised in Servicing Guide Announcement SVC-2014-16 that servicers now have discretion to waive Fannie Mae’s deficiency judgment rights if doing so will help resolve foreclosure delays based upon…more
| Finance & Banking, Real Estate - Residential

Foreclosure of DC Condominium Association’s Lien for Unpaid Assessments Extinguishes First Mortgage

(Chase Plaza Condominium Association, Inv. V. JP Morgan Chase Bank, No 13-CV-623 & 13-CV-674, decided August 28, 2014). In a case of first impression, the District of Columbia Court of Appeals held that a condominium…more
| Finance & Banking, Real Estate - Residential

Fannie Mae Announces Selling Guide Updates

On August 26, Fannie Mae issued Selling Guide Announcement SEL-2014-11, which advises that Fannie Mae is retiring two standard Fannie Mae ARM plans—ARM Plan 1445 and ARM Plan 1446—because certain revisions to Regulation Z and…more
| Labor & Employment Law, Finance & Banking, Real Estate - Residential

Federal District Court Defers To HUD On Disparate Impact Rule Burden-Shifting Framework

On September 3, the U.S. District Court for the Northern District of Illinois declined to invalidate to the burden-shifting framework established by HUD in its 2013 disparate impact rule, but remanded to HUD for further…more
| Finance & Banking, Insurance, Real Estate - Residential

Missouri Assembly Overrides Governor’s Veto Of Installment Lending Bill

On September 10, the Missouri General Assembly voted to override Governor Jay Nixon’s veto of SB 866, which defines traditional installment loans as “fixed rate, fully amortized, closed-end extensions of direct consumer loans”…more
| Conflict of Laws, Elections & Politics, Finance & Banking

SDNY Rejects Challenge To New York City’s Responsible Banking Law

On September 9, the U.S. District Court for the Southern District of New York dismissed an industry group’s challenge to a New York City ordinance that requires banks doing business with the city to report certain information…more
| Finance & Banking

FinCEN Rules Regulations on Money Services Businesses Do Not Apply to ISOs and Exempt Payment Processors

On August 27, FinCEN issued FIN-2014-R009, an administrative ruling clarifying that Independent Sales Organizations (“ISOs”) and exempt payment processors are not money transmitters subject to Bank Secrecy Act (“BSA”)…more
| Finance & Banking

FHFA Proposes Revised Eligibility Requirements for FHLB Membership

On September 2, the Federal Housing Finance Agency (FHFA) issued a proposed rule that would revise the requirements for financial institutions to apply for and retain membership in the Federal Home Loan Banks (FHLB)…more
| Finance & Banking, Real Estate - Residential
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