The Federal Financial Institutions Examination Council (“FFIEC”) published a statement on February 12, 2024 regarding “principles for the examination of supervised [institutions’] residential property appraisal and...more
La sección 6307 del Acto (“AML ACT of 2020”) requiere la capacitación anual para Examinadores sobre la lucha contra el lavado de dinero y el financiamiento del terrorismo. La capacitación debe realizarse en consulta con...more
On February 1, 2021, the Financial Industry Regulatory Authority (“FINRA”) released its “Report on FINRA’s Risk Monitoring and Examination Activities.” The Report combines two of FINRA’s long-standing reports: (a) the...more
Bank examinations, holding company inspections and other “supervisory events” can be a source of anxiety and dread for those who work in the banking industry. Originally published in ABA Bank Compliance - March/April 2020....more
El perfil de riesgo de la OFAC de una Institución Financiera se determina basado sus productos, servicios, clientes y ubicaciones geográficas. Se requiere que un programa de cumplimiento OFAC de una Institución Financiera...more
A Financial Institution’s OFAC risk profile is determined based on its products, services, customers and geographic locations. A Financial Institution’s OFAC compliance program is required to...more
The Annual Report provides transparency on FINRA’s recent examination findings and focus for the coming year. On October 16, 2019, the Financial Industry Regulatory Authority (FINRA) published its annual Report on...more
The Federal Financial Institutions Examination Council (FFIEC)—the interagency body tasked with setting uniform principles and standards for the examination of financial institutions by federal regulators, including the...more
The CFPB has generated acute awareness of the term “compliance management system” (CMS) through its highly publicized consent orders. Since it began issuing orders in 2011, the CFPB has invariably cited “significant...more
Georgia revised provisions under the Residential Mortgage Act, including, but not limited to, the following: An applicant for a mortgage lender license must provide a bond of $250,000, previously $150,000. This will...more
For investment adviser firms, an audit by the Securities and Exchange Commission or state regulators can be cause for anxiety. Regardless of how carefully a firm’s chief compliance officer adheres to regulations, deficiencies...more
At the program held on April 7 titled “The State of Consumer Protection Initiatives” at the American Bar Association Business Law Section Consumer Financial Services Committee 2017 Spring Meeting, Peggy Twohig, the CFPB’s...more
Private investment funds and advisers are likely to face new regulatory challenges and increased litigation risks in 2017, not only because of a change in the administration, but also because many advisers have not corrected...more
On January 4, FINRA released its Annual Regulatory and Examination Priorities Letter, which outlines the areas it plans to review over the coming year. FINRA President and CEO, Robert Cook, says that attention to these core...more
On January 4, new President and CEO Richard Cook issued FINRA’s Annual Regulatory and Examination Priorities Letter. This year’s list in summary is: New for 2017: Targeted electronic off-site reviews “on select...more
In late October, FINRA issued a sweep exam, commanding firms to produce 15 categories of documents about firm’s cross-selling programs over a 5-year span. The sweep seeks information on cross-selling, including incentives...more
In its Fall 2016 Supervisory Highlights, which covers supervision work generally completed between May and August 2016, the CFPB highlights violations found by its examiners involving origination and servicing of auto...more
- AXA Prevails at First Post-Jones v. Harris Excessive Fee Trial - Potential Secondary Effects of Regulatory Examinations: Evidentiary Issues and Preclusion in Parallel Litigation - On The Horizon: Global...more
Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more
On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The revised procedures...more
The Minnesota Department of Commerce recently conducted a series of routine exams of investment adviser firms registered in Minnesota to analyze their compliance with certain regulations applicable to investment advisers. ...more
A federal judge in Idaho has dismissed a $24 billion lawsuit against Credit Suisse alleging that the bank and real estate adviser Cushman & Wakefield ran a “predatory loan-to-own scheme that . . . loaded four luxury ski and...more
On June 24, 2016, in a response letter to Senator Dean Heller (R-NV), Daniel Tarullo, a member of the Board of Governors of the Federal Reserve System, highlighted the benefits of consistent cybersecurity supervisory...more
On November 6, 2015, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2015-42 to provide guidance on initial examinations of OCC-supervised institutions with the new Truth-in-Lending and Real Estate...more
The CFPB sent industry trade groups a letter on October 1, 2015 to address the approach of the Federal Financial Institutions Examination Council (FFIEC) member agencies during the initial months following the implementation...more