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Enforcement Actions Supervision

Goodwin

Supervisory Experience and Enforcement Actions Continue to Drive Supervisory Priorities and Policy Development

Goodwin on

This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more

WilmerHale

Interagency Issuances on Bank-Fintech Partnerships Highlights Risks, Opportunities, Importance of Industry Participant Engagement

WilmerHale on

The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’...more

Hudson Cook, LLP

[Webinar] CFPB Bites of the Month: Beware the Ides of March and the CFPB - March 15th, 2:00 pm - 2:30 pm ET

Hudson Cook, LLP on

We thank you for joining us over the past three years and are pleased to resume our CFPB Bites of the Month series in 2023! Consumer financial services concerns continue to be front and center in the daily news cycles....more

Hudson Cook, LLP

CFPB Bites of the Month - 2022 Annual Review

Hudson Cook, LLP on

In this article, we share a timeline of our monthly "bites" for 2022 applicable to the auto finance industry. So, what happened in 2022?...more

BakerHostetler

SEC Finds Investment Adviser CEO Liable for Failing to Supervise High-Risk Representative

BakerHostetler on

On Nov. 3, 2022, the SEC announced a consent order against a registered investment adviser (RIA) and its chief executive officer (CEO) for failing to reasonably supervise one of the RIA’s investment adviser representatives...more

Faegre Drinker Biddle & Reath LLP

And Now for the SEC’s First Substantive Reg BI Action

We have made it a point previously in this blog to track developments of the SEC’s Regulation Best Interest (Reg BI), even speculating more aggressive enforcement actions could be coming due to certain Reg BI deficiency...more

Faegre Drinker Biddle & Reath LLP

NYC Bar Association Proposes a CCO Enforcement Framework

Responding to a “concern” from Chief Compliance Officers (CCOs) to the purported increase in enforcement actions holding compliance personnel personally liable, the New York City Bar Association recently released a framework...more

Fox Rothschild LLP

Leaving Is The Hardest Part Especially If You Want To Re-Enter The Securities Industry

Fox Rothschild LLP on

We were recently reminded of how difficult it is to re-register for a position in the securities industry after being barred. See https://www.sec.gov/litigation/admin/2021/ia-5682.pdf. On February 9, 2021, the United...more

UB Greensfelder LLP

SEC Settlement Proves That When CCOs Spot A Problem, Silence Is Not Golden

UB Greensfelder LLP on

A long time ago, long before there existed any whistleblower statutes, I had a client – a CCO of a broker-dealer – who discovered some pretty funky trading at his firm. As he tells the story, when he went to see his boss (who...more

Faegre Drinker Biddle & Reath LLP

SEC Enforcement Victory in its Efforts to Police Cannabis Industry Investments

As the cannabis industry continues to evolve and generate capital raising and investment opportunities, the SEC Division of Enforcement will continue to closely keep watch and target the bad actors that new market...more

Faegre Drinker Biddle & Reath LLP

$125 Million Deutsche Bank Settlement with SEC/DOJ Newest in Line of Several Costly Resolutions

On January 8, 2021, the SEC issued a cease-and-desist order, Release No., 90875 (available here), formally resolving proceedings against Deutsche Bank AG. Deutsche Bank agreed to pay over $125 million as part of a global...more

UB Greensfelder LLP

Let’s Hear It For CCOs; After All, They Are Human People

UB Greensfelder LLP on

We have frequently blogged here about the degree of attention that regulators pay to Chief Compliance Officers, and whether it is proper that they sometimes are named individually in Enforcement actions. And we are hardly...more

UB Greensfelder LLP

How NOT To Supervise For Churning

UB Greensfelder LLP on

As should be clear to readers of this Blog, I find that Enforcement actions often provide the best guidance in terms of what regulators deem to be unacceptable conduct, which is very useful when dealing with subjective...more

Manatt, Phelps & Phillips, LLP

CFPB Enforcement: How the Latest Changes Impact Covered Entities

The Consumer Financial Protection Bureau (CFPB, or the Bureau) has announced major changes to its organizational structure, placing enforcement operations under the effective control of supervision. If finalized, this will be...more

Faegre Drinker Biddle & Reath LLP

CFTC Record Enforcement Year and Director Departure

On October 6, 2020, the Commodity Futures Trading Commission (“CFTC”) issued a release describing its record-breaking enforcement year. The release noted that in fiscal year 2020 (“FY2020”), the CFTC filed more enforcement...more

Goodwin

SEC Charges Trust Company With Operating Unregistered Investment Companies

Goodwin on

SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more

Faegre Drinker Biddle & Reath LLP

CFTC Enforcement Update: A Spoofing Record Breaker & More on “Insider Trading”

On August 19, 2020, the Commodity Futures Trading Commission (“CFTC”) issued three orders filing and settling charges against a bank with a provisionally registered swap dealer (the “Firm”) requiring the Firm to pay $127.4...more

Health Care Compliance Association (HCCA)

Report on Research Compliance Volume 17, Number 2. January 2020: In This Month’s E-News: February 2020

Report on Research Compliance 17, no. 2 (January 23, 2020) - - More than two years after Ozgur Tataroglu’s paper was retracted, the HHS Office of Research Integrity found that it and two grant applications contained...more

WilmerHale

New Commission Moves Quickly on Enforcement

WilmerHale on

Within a week of the ceremonial swearing in of its last commissioner, the now fully formed Commodity Futures Trading Commission (Commission or CFTC) issued 17 enforcement orders and filed one complaint. These initial...more

Bracewell LLP

FINRA Fines Lincoln Financial Sub $650,000 For Cybersecurity Shortcomings

Bracewell LLP on

A Lincoln Financial Group subsidiary agreed to pay $650,000 to the Financial Industry Regulatory Authority (FINRA) to resolve allegations that it failed to implement sufficient security policies to protect confidential...more

Proskauer Rose LLP

CFTC Brings Enforcement Action for Swap Reporting Violations

Proskauer Rose LLP on

The Commodity Futures Trading Commission (CFTC) recently brought its first enforcement action arising from the Dodd-Frank requirement that swap transactions be reported to a registered swap data repository (SDR). The CFTC has...more

Ballard Spahr LLP

Supervisory or Enforcement Action? Deputy Director Explains How the CFPB Decides

Ballard Spahr LLP on

In his prepared remarks for an appearance last month at the Exchequer Club, Consumer Financial Protection Bureau Deputy Director Steven Antonakes discussed the CFPB’s risk-based approach to supervision. (The Exchequer Club’s...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Germany: High-Profile Enforcement Actions and Increased Cartel Prosecution Dominate Enforcement Landscape"

Several high-profile corporate criminal investigations and prosecutions in Germany have led to the scrutiny of directors and officers for failure of controls and supervision. Several recent notable German enforcement actions...more

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