A Look at Recent Federal Trade Commission and Consumer Financial Protection Bureau Initiatives Concerning Privacy and Data Security
2BInformed: Engaging with EPA, OSHA’s New Regulation, and Asbestos
The Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) Board issued an Advanced Notice of Proposed Rulemaking (“ANPR”) titled “Resolution-Related Resource Requirements for Large Banking...more
Regulatory Announcements- FTC Announces Agenda for October 2022 Open Commission Meeting. On October 13, the FTC announced the agenda for its October 20, 2022 Open Commission Meeting. Specifically, the agency announced that...more
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more
In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more
In this issue, we discuss the new initiatives under New York's BitLicense regime that clarify and streamline the regulatory landscape for virtual currency entities doing business within the state. We also examine the...more
In This Issue. The Securities and Exchange Commission (SEC) finalized amendments to its proxy solicitation rules that will modify the practices of proxy advisory firms, providing them with greater transparency and...more
On July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued an interpretive letter confirming that national banks and federal savings associations (banks) may provide cryptocurrency custody services to...more
Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more
On June 3, 2020, the Office of the Comptroller of the Currency (OCC) published an advance notice of proposed rulemaking (ANPR) to solicit public input on the “digital activities” of banks and the impact of emerging...more
For the first time in a dozen years, the Office of the Comptroller of the Currency (OCC) is seeking to update its regulations on digital activities to consider banks’ use of blockchain and distributed ledger technology (DLT),...more
The OCC has issued an Advance Notice of Proposed Rulemaking (ANPR) seeking comments in connection with a comprehensive review of its regulations on electronic activities of national banks (12 CFR part 7, subpart E) and...more
In This Issue. The Office of the Comptroller of the Currency (OCC) released an advanced notice of proposed rulemaking seeking comments on several issues related to digital technology and innovation, as well as proposed...more
On May 29, 2020, Joseph Otting stepped down as Comptroller of the Currency, and Brian Brooks was named Acting Comptroller. In his opening remarks, Acting Comptroller Brooks outlined his priorities, the first of which...more
On June 1, 2020, the Office of the Comptroller of the Currency (“OCC”) released a final rule on permissible interest on loans that are sold, assigned, or transferred, and effectively reversed the Second Circuit’s 2015...more
On Thursday, December 12, 2019, the OCC and the FDIC issued a notice of proposed rulemaking (NPR) in an effort to modernize the regulatory framework behind the Community Reinvestment Act (CRA). Last autumn, renewed...more
On Monday, September 9, 2019, a group of 28 housing, consumer protection and community development organizations issued a letter to the Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency and...more
In This Issue. The Consumer Financial Protection Bureau (CFPB) announced its intention to allow the “QM Patch,” which exempts Fannie Mae and Freddie Mac from the full scope of the ability-to-repay/qualified mortgage rule, to...more
EDITOR'S NOTE - Working Weekends and Holidays. While most Americans were enjoying the Independence Day holiday weekend, the Board of Governors of the Federal Reserve System (Federal Reserve), the Office of the Comptroller of...more
On April 29, 2019, the Office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) to solicit comment on whether it should issue a formal proposal to expand the reach of its...more
The OCC recently issued an advance notice of proposed rulemaking (ANPR) regarding the scope of activities that are fiduciary in nature, as well as the requirements of non-fiduciary custody activities of national banks,...more
On March 19, 2019, the New York State Department of Financial Services (“NYDFS”) filed a brief in opposition to the Office of the Comptroller of the Currency’s (“OCC”) motion to dismiss the NYDFS’ lawsuit challenging the...more
The Office of the Comptroller of the Currency (OCC) is soliciting public comment on possible revisions to its regulations implementing the Community Reinvestment Act (CRA). The OCC is seeking input on ways to better define...more
The U.S. Office of the Comptroller of the Currency issued an advanced notice of proposed rulemaking with respect to the modernization of the Community Reinvestment Act. The notice highlights that a revised CRA framework will...more
The Office of the Comptroller of the Currency (OCC) has issued an advance notice of proposed rulemaking (ANPR) on which it invites public comment “to solicit ideas for building a new framework to transform or on ways to...more