Financial Institutions

News & Analysis as of

FINRA Provides Guidance on Liquidity Risk Management Practices

The Financial Industry Regulatory Authority has issued Regulatory Notice 15-33 to provide guidance on liquidity risk management practices for senior management and risk managers to consider and implement....more

On the application of personal sanctions by Ukrainian banks

By a new Resolution of the National Bank of Ukraine (the "NBU") No. 654 dated 1 October 2015 (the "Resolution") a procedure on application of sanctions was introduced....more

FCA announces fall in complaints

FCA has announced a decrease in complaints received between January and June 2015 of 2.1% compared to the previous six months. This has largely been driven by the fall in PPI-related complaints. However, complaints about...more

Agencies Unveil Student Loan Servicing Regulatory Framework

On September 29, the CFPB issued a report examining public comments and providing policy recommendations to address issues in the student loan servicing market. The report follows a May 2015 Request for Information notice...more

CFPB Continues to Target Add-On Credit Products

The Consumer Financial Protection Bureau (CFPB) has stepped up its enforcement actions alleging deceptive and unfair practices in marketing and billing for add-on credit protection products. Add-on products have been one of...more

OCC Released Update to the Bank Accounting Advisory Series

On September 29, the Office of the Comptroller of the Currency released an update to the Bank Accounting Advisory Series (the “BAAS”). The goal of the BAAS is to promote consistent application of accounting standards among...more

Prepare Your Brewery or Distillery to Raise Money

Raising capital can be very exciting, but it can also create a great deal of uncertainty and anxiety. Before you approach a bank, an individual investor, or a more institutional equity investor, be aware that these people...more

FinCEN to Withdraw 2011 Proposed Rule Against Lebanon-Based Bank

On September 28, FinCEN announced its intention to withdraw its February 2011 Notice of Finding and Notice of Proposed Rulemaking identifying a Lebanon-based bank as a “financial institution of primary money laundering...more

HUD, FDIC, and U.S. Attorney File Suit Against Mortgage Lending Companies

On September 28, HUD, the FDIC, and the U.S. Attorney for the Eastern District of New York filed suit against a non-profit housing counseling corporation and certain mortgage lenders for allegedly running a scheme to defraud...more

AFME publishes model BRRD clause for bail-in recognition

AFME has published a model clause for the contractual recognition of bail-in. It is for use by UK issuers of New York law governed debt securities who are subject to the requirements of article 55 of the Bank Recovery and...more

Global Regulators Evolve on Money Manager Systemic Risks

The Board of the International Organization of Securities Commissions (IOSCO) in June made an important recommendation concerning any risks that investment funds and advisors present to the global financial system....more

BBA updates Lending Code

BBA and the UK Cards Association have published a revised version of the Lending Code. This self-regulatory code sets standards of good practice when dealing with consumers, micro-enterprises and small charities in the UK for...more

Virtual Currencies: International Actions and Regulations

This chart is provided by Perkins Coie LLP’s Decentralized Virtual Currency industry practice group for informational purposes only and is not legal advice. This information is not intended to create, and receipt of it does...more

Banking Standards Review Board publishes Lambert standards responses

The Banking Standards Review Board has published the responses to the 2014 review by Sir Richard Lambert on banking standards. ...more

CFPB’s Credit Union Advisory Council to meet on October 8

A meeting of the CFPB’s Credit Union Advisory Council has been scheduled for October 8, 2015 at the CFPB’s offices in Washington, DC. The agenda indicates that the “Council will discuss consumer challenges in payments.”...more

FSB reports to central bank governors

FSB has released its three reports to G20, which it provided ahead of the G20 meeting in early September. The reports cover: - corporate funding structures and incentives...more

Securitisation: Keeping it Simple?

On 30 September 2015, the European Commission (the “Commission”) published a proposal for a regulation (the “Proposed Regulation”)1 intended to harmonise existing EU laws applying to securitisations (including proposed...more

EBA consults on harmonised definition of default

EBA is consulting on draft guidelines under the Capital Requirements Regulation (CRR) to harmonise the definition of default across the EU prudential framework, which is intended to bring consistency in the way EU banks apply...more

EBA issues DGS guidelines translations

EBA has published the translations into all official EU languages of its final guidelines on contributions to deposit guarantee schemes (DGS) and on payment commitments under the revised Deposit Guarantee Schemes Directive...more

New York City’s RBA Falls to Preemption Challenge

New York City banks are breathing a sigh of relief after a federal judge ruled that they would not have to provide detailed servicing disclosures under a preempted city law. The law, a gloss on top of the federal Community...more

Federal Reserve To Require Same-Day ACH Service

On September 23, the Federal Reserve Board announced the approval of “enhancements” to the Federal Reserve Banks’ same-day automated clearing house (ACH) service. According to the Fed, “[t]he enhancements are intended to...more

Credit Card Fraud: EMV compliance and shift of liability as of October 1

As of October 1, 2015, all major credit card companies in the United States (including, Visa, MasterCard, Discover and American Express) will impose a liability shift for counterfeit presentation of payment cards. In the...more

FCA Publishes New Supervisory Approach for Regulated Firms in UK

On September 18, the UK Financial Conduct Authority (FCA) published two papers with new guidance (the “Guides”) regarding how it will supervise different types of UK regulated financial services firms in the future. ...more

CFPB and DOJ Fine Savings Association Over Alleged Mortgage Redlining Practices

On September 24, the CFPB and DOJ announced a joint enforcement action against a federally-chartered savings association, alleging that the lender excluded predominantly minority neighborhoods from its mortgage lending...more

"Evaluating the State of Financial Reform Five Years After Dodd-Frank"

July 21, 2015, marked the fifth anniversary of the signing of the landmark Dodd-Frank Act and provided a natural opportunity to evaluate the progress regulators have made in establishing the new regulatory regime as well as...more

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