Financial Institutions

News & Analysis as of

New York Financial Services Cybersecurity Regulations Go Into Effect on March 1st

We have previously reported about the upcoming New York Financial Services Cybersecurity Regulations. On February 16, 2017, Governor Andrew M. Cuomo announced that “the first-in the-nation cybersecurity regulation to protect...more

Update: Prudential Regulators Delay Compliance Deadline for New Swap Margin Rules

If you have been following our alerts on the pending deadlines (and the delays of these deadlines by certain regulators) of the new swap variation margin rules (New Swap Margin Rules) that were due to go into effect on March...more

The “Final Final” is Here: NYDFS Cybersecurity Regulations

As Hogan Lovells previously reported, the New York State Department of Financial Services (NYDFS) has launched a significant initiative to impose detailed cybersecurity requirements on covered financial institutions. On...more

New York State Department of Financial Services Issues Final Cybersecurity Regulations

On February 16, 2017, the New York State Department of Financial Services ("DFS") issued final cybersecurity regulations (the "Final Regulations"), with extensive requirements for cybersecurity programs by entities regulated...more

NY DFS Cybersecurity Regulations Take Effect March 1, 2017

We previously reported on the New York Department of Financial Services’ proposed cybersecurity regulations. During the public comment period, the DFS received over 150 comments. In response, the DFS announced on December 28,...more

Reporting of U.S. Ownership on TIC Form SHC Due by March

The U.S. Department of the Treasury (“Treasury”) is currently collecting data from U.S. institutions in connection with its mandatory five-year benchmark survey of the ownership of foreign securities by U.S. residents. For...more

Qatar: A Promising Start

Originally published in Islamic Finance News - February 22nd, 2017. The last month presented an opportunity to reflect on the performance of the banking sector in Qatar during the past year, with the majority of the...more

New York Institutions: Exemption from Cybersecurity Regulations Sought by Bond Granted in Final Regulations Issued by Department...

Last month, Bond, Schoeneck & King sought an exemption from cybersecurity regulations proposed by the New York State Department of Financial Services (DFS) for colleges, universities and other charitable organizations that...more

Automatic exchange of information and insurance companies - a question of compliance

Automatic exchange of information (AEOI) regimes, primarily aimed at curbing tax avoidance through the use of foreign accounts and investment platforms, have recently become a global trend, starting with the adoption of the...more

Orrick's Financial Industry Week In Review

Financial Industry Developments - New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation - On February 16, 2017, the New York Department of Financial Institutions...more

One of a Kind: NYDFS Cyber Rule Finalized, Effective March 1, 2017

The closely watched New York State Department of Financial Services (NYDFS) cybersecurity standards for covered financial institutions are now final and take effect March 1, 2017 in less than a week. The final rule largely...more

For Our Eyes Only: Understanding the Attorney-Client Privilege and Its Application to Banks

The attorney-client privilege is a rule of evidence that prevents the adverse party in a lawsuit from obtaining access to certain communications. If properly understood and wellmanaged, this privilege offers a useful tool for...more

FinCEN Renewal of GTOs for High-End Cash Buyers in Six Markets

FinCEN announced today that it is renewing the existing Geographical Targeting Orders (GTOs) issued in July 2016 that require all title insurance companies to identify and report on the natural persons behind shell companies...more

European Parliament Publishes Provisional Version of Resolution It Has Adopted on Its 2016 Report on Banking Union

The European Parliament has published a draft of the text of the resolution it has adopted on its annual report on banking union. The Parliament’s resolution is divided into themes, these being resolution, supervision and...more

Sony Cyber-Attackers Lurking at Financial Supervisor “Watering Hole” Target Banks and Others

Cybersecurity specialists at BAE Systems and Symantec announced last week new evidence suggesting that the criminals behind the notorious 2014 attack on Sony Corp. are also responsible for recent cyber-attacks involving 104...more

The New York Department of Financial Services Issues Its Final Cybersecurity Regulation

On February 16, 2017, the New York Department of Financial Services (“DFS”) issued the final version of its cybersecurity regulation. The regulation, which has seen several iterations since it was first proposed in September...more

New York Finalizes Cybersecurity Regulations for Financial Institutions

On February 16, the New York State Department of Financial Services (NYDFS) issued cybersecurity regulations for banks, insurance companies and other financial institutions subject to NYDFS jurisdiction. ...more

OCC Establishes New Third-Party Risk Management Expectations, Including for Bank Relationships With Marketplace Lenders

The bulletin requires relationships between banks and marketplace lenders to be treated with the same rigor of due diligence and ongoing oversight as other relationships with third parties. On January 24, the Office of...more

Bitcoin and Blockchain Technology Update: Research Paper

Locke Lord London Global Head of Cards & Payments Robert Courtneidge and Associate Charlie Clarence-Smith wrote a research paper on bitcoin and blockchain technology. Over the past few years, digital currencies have been...more

New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation

On February 16, 2017, the New York Department of Financial Institutions (“DFS“) promulgated a regulation that requires “Covered Entities” to establish and maintain a cybersecurity program designed to protect consumers and the...more

DFS Final Cyber Regulation: Accountability at the Top

Over the last few months, the New York Department of Financial Services (“DFS”) cybersecurity regulation has undergone multiple revisions. But late last week, DFS issued its final regulation, which will go into effect on...more

Navigating Through the Hazy Intersection of Financial Services and the Legal Marijuana Industry

As more states legalize marijuana use, financial institutions face increased uncertainty about how to handle accounts opened by marijuana-related businesses (MRBs) in light of regulatory difficulties stemming from the obvious...more

CSBS Releases BSA/AML Risk and Controls Self-Assessment Tool

The Conference of State Bank Supervisors (CSBS) has continued its efforts to promote improvements in Bank Secrecy Act/Anti-Money Laundering compliance with the release in January 2017 of a new BSA/AML Self-Assessment Tool for...more

CFPB Evaluates Use of Alternative Data and Modeling Techniques in the Consumer Lending Credit Process

On February 16, 2017, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a Request for Information (RFI) regarding use of alternative data and modeling techniques in the consumer lending “credit process.” The...more

FinCEN Issues Advisory on Jurisdictions with AML/CFT Deficiencies

The Financial Crimes Enforcement Network (“FinCEN”), an agency within the U.S. Treasury Department, has put forth an Advisory on the FATFIdentified Jurisdictions with AML/CFT (Anti-Money Laundering/Combating the Financing of...more

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Cybersecurity

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