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Risk Management Financial Institutions

Cadwalader, Wickersham & Taft LLP

The PRA and the Treatment of Overseas Branches

The UK’s banking regulator, the Prudential Regulation Authority ("PRA") has issued a consultation on its approach to the treatment of branches of international banks operating in the UK (CP11/24). Among the proposals is a...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Barnea Jaffa Lande & Co.

Regulation in the Past Year: A Summary of Key Changes and Outlook for the Future

Most of the focus over the past year has been on the events of October 7 and the ensuing war. Not only the citizens, but also the legislative and regulatory authorities in Israel have been devoting most of their time to deal...more

A&O Shearman

European Central Bank Supervisory Board Speech on Banks' Operational Resilience

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The European Central Bank has published a speech by Frank Elderson, ECB Executive Board member and Supervisory Board Vice-Chair, on banks' operational resilience. Operational resilience has become a key priority for...more

Tenace

Outsourcing Financial Services: When, Why, and How to Make the Move

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In today’s fast-paced and complex business environment, companies of all sizes are turning to outsourcing at an increased rate as a strategic solution to streamline operations, reduce costs, and focus on their core...more

Troutman Pepper

Where the F(BO) Is the Money? Part 1 – Synapse’s Clarion Call for Standards

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This is the first of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Informed Board - Summer 2024

Across industries, companies are facing new and uncertain regulatory pressures and demands in areas including artificial intelligence, sustainability, algorithmic pricing and fintech-bank relations. In this issue of The...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Standard Formula: A Guide to Solvency II – Chapter 10: Governance Requirements

Solvency II is organised around three core pillars of prudential regulation, which ensure the safety and soundness of (re)insurers, in line with the scale, nature and complexity of their business: - Pillar One focuses on...more

Mayer Brown

HKMA Enhanced Consumer Protection in the Use of GenAI by Authorized Institutions in Hong Kong

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The Hong Kong Monetary Authority (HKMA) has imposed additional principles on the use of big data analytics and artificial intelligence (BDAI) and specifically, generative artificial intelligence (GenAI) by authorized...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Why do Fintechs Want to Become Banks?

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A great number of fintechs are contemplating owning a bank or obtaining a banking charter—either a national bank charter, a state bank charter or a special purpose charter. In this episode, we are joined by our special guest...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - August 2024 # 3

Troutman Pepper on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

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The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

Mayer Brown

Interview with Jason Cave, Former Regulator Turned Industry Adviser

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Matt Bisanz interviews former financial regulator Jason Cave to discuss developments in resolution and recovery planning, as well as trends in third-party risk management....more

Orrick, Herrington & Sutcliffe LLP

GOP Senators express concern on FDIC proposed rules regarding corporate governance and risk management

On July 31, Republican members of the U.S. Senate penned a letter to the Chairman of the FDIC, Martin Gruenberg, to convince the Chairman that an FDIC proposed rule regarding soundness standards for corporate governance and...more

Cadwalader, Wickersham & Taft LLP

Banking Regulators’ Request for Information on Bank-Fintech Arrangements

On July 25, 2024, the Fed, the OCC and the FDIC (the “Banking Regulators”) released a “Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses” (the...more

Alston & Bird

Regulators Focus on Bank-Fintech Arrangements

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Through joint guidance and an information request, federal bank regulators underscored banks’ compliance responsibilities in their banking-as-a-service (BaaS) relationships with third parties. Our Financial Services Team...more

Troutman Pepper

FDIC Proposal Would Classify More BaaS Deposits as Brokered, Not Core

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“I would say a lot of these fintechs deposits are actually the opposite of hot money,” said Matthew Bornfreund, a partner at Troutman Pepper. “I think a problem with this proposed rulemaking is, the FDIC asserts that these...more

WilmerHale

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

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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

Morrison & Foerster LLP

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

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On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

Skadden, Arps, Slate, Meagher & Flom LLP

The PRA’s Expectations for Funded Reinsurance: How To Comply

The PRA has released an important statement on its approach to funded reinsurance. Our view is that the statement endorses the conceptual principle that funded reinsurance (particularly to offshore counterparties) should best...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Nutter McClennen & Fish LLP

Nutter Bank Report: July 2024

The federal banking agencies have published joint guidance for banks about risks posed by fintech companies and other third parties to deliver bank deposit products and services. The joint guidance issued on July 30...more

Ballard Spahr LLP

Banking Regulators Seek Comment on Third-Party Relationships with Financial Institutions

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The federal banking regulators are seeking comment to better understand the relationship between financial institutions and third parties that work for them....more

Ballard Spahr LLP

Regulators Outline Risks that Third-Party Servicers Pose to Banks

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Banking regulators have issued a joint statement outlining the potential risks that financial institutions face in arrangements with third parties to deliver bank deposit products and services and examples of risk management...more

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