News & Analysis as of

Covered Financial Institutions

New CFPB webinar available on 2015 HMDA final rule

by Ballard Spahr LLP on

On October 15, 2015, the CFPB released a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA), requiring certain data on mortgage applications and loans to be collected beginning in 2017...more

CFPB revises methodology statement for calculating average prime offer rates

by Ballard Spahr LLP on

The CFPB has published a notice in the Federal Register announcing that it has revised its methodology statement for calculating the average prime offer rates (APORs) under Regulations C and Z. Regulation C requires...more

What Community Banks of All Sizes Need to Know About the Proposed Interagency Rulemaking on Incentive Compensation

by Balch & Bingham LLP on

The federal banking supervisors have jointly published 285 pages of proposed rules on incentive-based compensation practices, as required by the Dodd-Frank legislation enacted in 2010. The proposed rules only apply to banks...more

The New AML Regulations and Their Impact on Banks—Increased Compliance for Lending Transactions with Legal Entities

by Dorsey & Whitney LLP on

On May 11, 2016, FinCEN published in the Federal Register its long-awaited anti-money laundering (“AML”) rules (the “Final Rules”) governing corporate entities doing business with banks and other financial institutions that...more

Federal Agencies Release Joint Proposed Rule on Financial Institution Incentive-Based Compensation

Last month, consistent with their obligation under the Dodd-Frank Act, several federal agencies released for comment a joint proposed rule that would prohibit any incentive compensation that encourages inappropriate risk...more

Anti–Money Laundering Alert: FinCEN Finalizes Beneficial Ownership and Customer Due Diligence Requirements

by WilmerHale on

The Financial Crimes Enforcement Network (FinCEN) on May 11 released its long-awaited Final Rule (CDD Rule) that will require certain financial institutions to “look through” the nominal account holder to identify the...more

Recent Investment Management Developments - May 2016

by Ballard Spahr LLP on

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management...more

FinCEN AML/BSA Amendments Require Beneficial-Owner Look-Through

by Burr & Forman on

In AML/BSA rule amendments published May 11, FinCEN will require “covered financial institutions” to implement new beneficial-owner identification and verification as part of their Customer Due Diligence (“CDD”) and adopt...more

FinCEN Customer Due Diligence Final Rules

On May 5, 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued final rules (the Final Rules) on customer due diligence requirements for banks, securities broker-dealers, mutual funds, and...more

FinCEN Finalizes Beneficial Ownership Identification Rules

by Ballard Spahr LLP on

As part of the U.S. Treasury Department's ongoing efforts to prevent bad actors from using U.S. companies to conceal money laundering, tax evasion, and other illicit financial activities, the Financial Crimes Enforcement...more

Big Data, Big Government – Big Trouble? A Hard Look at the Final HMDA Rule

by Morrison & Foerster LLP on

If all goes according to plan, financial institutions will report over 250 million data points related to mortgage loan applications and originations in 2018. If the mortgage market returns to the high volumes seen in 2005,...more

CFPB Issues New Mortgage Disclosure Rule

by Goodwin on

On October 15, 2015, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). At nearly 800 pages, the new HMDA rule changes (i) the...more

HOLY HMDA! CFPB Finalizes Changes to Home Mortgage Disclosure Rule

by Morrison & Foerster LLP on

On October 15, 2015, the CFPB released a final rule amending Regulation C, 12 C.F.R. part 1003, which implements the Home Mortgage Disclosure Act (HMDA). Like the August 2014 proposed rule, the final rule includes changes to...more

FinCEN Final Rule on Foreign Bank Requires Covered Financial Institutions to Take “Special Measures”

by McGuireWoods LLP on

On July 22, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published in the Federal Register a final rule pursuant to Section 311 of the Patriot Act against FBME Bank Ltd. (FBME,...more

Volcker Rule: New FAQs Regarding Foreign Public Funds and Joint Venture Covered Fund Exclusions

by Morgan Lewis on

Additional guidance issued five weeks before the July 21, 2015 conformance date. On June 12, the five federal agencies jointly responsible for implementing the Volcker Rule (the Agencies) released two new “Frequently...more

FinCEN Proposes New Rule Requiring Identification of Beneficial Owners

by Shearman & Sterling LLP on

This summer the Financial Crimes Enforcement Network ("FinCEN”) issued a notice of proposed rulemaking proposing a rule that, if adopted, would mandate that financial institutions require their legal entity customers to...more

FinCEN Proposes More Extensive Customer Due Diligence Obligations

by Ballard Spahr LLP on

As part of the U.S. Treasury Department’s ongoing efforts to combat all forms of illicit financial activity, from terrorist financing and sanctions evasion to more traditional financial crimes (including money laundering,...more

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Cybersecurity

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