Alexander Callen on Comment Period

FDIC Proposes Guidelines Establishing Standards for Corporate Governance and Risk Management for Covered Institutions with Total...

On October 3, 2023, the Federal Deposit Insurance Corporation (FDIC) approved proposed guidelines establishing standards for corporate governance and risk management for covered institutions with total assets of $10 billion...more

11/16/2023 / Banking Sector , Board of Directors , Comment Period , Corporate Governance , Covered Financial Institutions , Dodd-Frank , FDIC , Financial Institutions , Proposed Guidance , Risk Management

Federal Banking Agencies Propose Basel III Endgame Capital Rules

On July 27, 2023, the Federal Reserve, FDIC, and OCC issued a notice of proposed rulemaking and request for comment on a proposal (the Proposal) to implement the final components of the Basel III Capital Accords, often...more

8/4/2023 / Banking Crisis , Banking Regulators , Banking Sector , Basel III , Capital Requirements , Comment Period , FDIC , Federal Reserve , Financial Institutions , Financial Regulatory Reform , Large Financial Institutions (LFIs) , OCC , Proposed Regulation , Silicon Valley , Systemic Risk Buffer

FinCEN Proposes Rules Implementing Corporate Ownership Requirements Under Corporate Transparency Act to Fill Gaps in U.S....

WHAT YOU NEED TO KNOW: - The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule to implement portions of the Corporate Transparency Act codified at 31 U.S.C. § 5336...more

12/22/2021 / Anti-Money Laundering , Beneficial Owner , Business Entities , Comment Period , Corporate Transparency Act , Exemptions , FinCEN , Pooled Investment Vehicles , Proposed Rules , Public Comment , Reporting Requirements

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

SEC Raises Concerns About Misleading ESG Practices, Highlights Potential Violations

In This Issue. The U.S. Securities and Exchange Commission (SEC) Division of Examinations issued a Risk Alert raising concerns about misleading Environmental, Social, and Governance (ESG) disclosures by investment firms; the...more

4/20/2021 / Advertising , Anti-Money Laundering , Bank Secrecy Act , Banking Sector , BSA/AML , Comment Period , Environmental Social & Governance (ESG) , Fannie Mae , FDIC , Federal Reserve , Freddie Mac , Notice of Proposed Rulemaking (NOPR) , Public Comment , Reporting Requirements , Risk Alert , Risk Management , Securities and Exchange Commission (SEC) , Supervisory Guidance

CFPB Proposes Mortgage Servicing Changes; Supreme Court Weighs in on TCPA

In This Issue. The Consumer Financial Protection Bureau (CFPB) continued to be active under its new leadership this week, warning mortgage servicers to prepare now for an anticipated surge of homeowners needing assistance...more

Biden Administration Issues Regulatory Freeze On New Agency Rules

In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

1/29/2021 / Anti-Money Laundering , Appeals , Banking Sector , Biden Administration , Borrowers , Carried Interest , Comment Period , Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Cryptocurrency , Debt Relief , Debtors , Digital Assets , Enforcement Actions , Fair Access to Credit , FDIC , Fees , Final Report , Final Rules , Financial Regulatory Agencies , Financial Services Industry , FinCEN , Internal Revenue Code (IRC) , Lenders , Misrepresentation , Mortgage Lenders , New Rules , OCC , Popular , Public Comment , Regulatory Freeze , Ripple , Securities and Exchange Commission (SEC) , Securities Violations , Settlement Agreements , Student Loans , Supervisory Guidance , Suspicious Activity Reports (SARs) , Unlawful Practices , Unregistered Securities , Virtual Currency

FDIC Finalizes Brokered Deposits and ILC Rules Ahead of the Holidays

In this Issue. The Federal Deposit Insurance Corporation (FDIC) was busy this week, finalizing rules that modernize brokered deposits regulations, establish new standards for parent companies of industrial loan companies and...more

12/17/2020 / §314(b) , Banking Sector , Branch Offices , Brokered Deposits , Brokers , Comment Period , Consumer Financial Protection Act (CFPA) , Consumer Financial Protection Bureau (CFPB) , Consumer Loan Companies , Cyber Incident Reporting , Cybersecurity , Debt Collection , Disclosure Requirements , Environmental Policies , Fair Credit Reporting Act (FCRA) , FDCPA , FDIC , Federal Bank Regulatory Agencies , Federal Reserve , Final Rules , Financial Reporting , Financial Services Industry , Historic Preservation , Information Sharing , Investment Adviser , Investment Management , Investors , MD&A Statements , NEPA , NHPA , Notice of Proposed Rulemaking (NOPR) , OCC , Paycheck Protection Program (PPP) , Proposed Rules , Public Comment , Qualified Mortgage Rule , Registered Funds , SBA , Securities and Exchange Commission (SEC) , Securities Litigation , Securities Regulation , Suspicious Activity Reports (SARs)

OCC Proposes Rules for CRA Benchmarks and Fair Access

In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more

11/30/2020 / Bank Secrecy Act , Banking Sector , Benchmarks , Charitable Organizations , Comment Period , Community Reinvestment Act , Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Coronavirus/COVID-19 , Debt Buyers , Debt Collection , Derivatives , Disclosure Requirements , Document Retention Policies , Due Diligence , Fannie Mae , FDIC , FHFA , Final Rules , Financial Adviser , Financial Services Industry , Freddie Mac , Interim Final Rules (IFR) , Investment Adviser , Lenders , MD&A Statements , Mutual Funds , Nonprofits , Notice of Proposed Rulemaking (NOPR) , OCC , OCIE , Private Investment Funds , Proposed Rules , Public Comment , Registration Statement , Regulation M , Regulation S-K , Regulation S-T , Regulation Z , Regulatory Requirements , Relief Measures , Reporting Requirements , Risk Alert , Securities and Exchange Commission (SEC) , Securities Exchange Act , Student Loans , Supervisory Guidance

Federal Reserve Proposes Rules To Modernize Regulations That Implement CRA

In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more

SEC Stays Busy With Amendments And Extensions To Various Rules, Definitions And Disclosures

In the News. The Securities and Exchange Commission (SEC) adopted final rules to update and expand the statistical disclosures that bank and savings and loan registrants must provide to investors for the first time in 30...more

9/17/2020 / Accredited Investors , Amended Rules , Anti-Money Laundering , Banking Sector , Banks , Brokers , Comment Period , Consumer Financial Protection Bureau (CFPB) , Coronavirus/COVID-19 , Crowdfunding , Data Collection , Deposit Insurance , Disclosure Requirements , Disparate Impact , Dodd-Frank , Extensions , Fair Credit Reporting Act (FCRA) , FDIC , Federal Reserve , Federal Trade Commission (FTC) , Filing Fees , Final Rules , Financial Reporting , Financial Services Industry , FinCEN , Flood Insurance , HUD , Interim Final Rules (IFR) , Investors , Leverage Ratio , Notice of Proposed Rulemaking (NOPR) , OCC , Public Comment , Qualified Institutional Buyers , Relief Measures , Savings and Loan Companies , Section 1071 , Securities and Exchange Commission (SEC) , Small Business , Temporary Regulations , Time Extensions

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

8/28/2020 / Abuse of Discretion , Alternative Reference Rates Committee (ARRC) , Appeals , Arbitrary and Capricious , Bank Secrecy Act , Banking Sector , Banks , Best Practices , CARD Act , Carried Interest , Comment Period , Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Credit Cards , Credit Discrimination , Delays , Depository Institutions , Due Diligence , Enforcement Actions , Fannie Mae , FDIC , Federal Deposit Insurance Act , Fees , FHFA , Final Rules , Financial Institutions , Financial Services Industry , FinCEN , Freddie Mac , GSE , Interim Final Rules (IFR) , Joint Statements , Libor , Loan Forgiveness , Loans , OCC , Paycheck Protection Program (PPP) , Policy Statement , Predatory Lending , Proposed Regulation , Public Comment , Refinancing , Regulatory Requirements , Request For Information , Rulemaking Process , SBA , Small Business , Small Business Loans

Financial Services Weekly Roundup: SEC Proposes Modified Disclosure Framework For Funds

In the News. The Securities and Exchange Commission (SEC) proposed modifying the disclosure framework for mutual funds and exchange-traded funds (funds), which would create a new layered disclosure regime that attempts to...more

8/14/2020 / Alternative Reference Rates Committee (ARRC) , Annual Reports , Banking Sector , Banks , Board of Governors , Borrowers , Business Development Companies , Capital Requirements , Closed-End Funds , Comment Period , Coronavirus/COVID-19 , Disclosure Requirements , Enforcement Actions , Excessive Fees , Exchange-Traded Products , Federal Reserve , Fees , Financial Services Industry , Form N-1A , Interim Final Rules (IFR) , Investment Adviser , Investment Companies , Investment Company Act of 1940 , Investment Funds , Investment Management , Investors , Lenders , Libor , Loan Forgiveness , Municipal Liquidity Facility (MLF) , Mutual Funds , OCC , Paycheck Protection Program (PPP) , Public Comment , Registered Funds , Retail Investors , Rule 30e-3 , SBA , SEC Advertising Rule , Section 36(b) , Secured Overnight Funding Rate (SOFR) , Securities and Exchange Commission (SEC) , Shareholders

2/6/2020 / Abusive Acts , Alternative Reference Rates Committee (ARRC) , Bank Holding Company , Bank Holding Company Act , Banking Sector , Board of Governors , CFTC , Comment Period , Consumer Financial Protection Bureau (CFPB) , Controlling Influence Test , Covered Funds , Disclosure Requirements , Dodd-Frank , Federal Reserve , FHFA , Final Rules , Financial Services Industry , Financial Statements , Investment Management , Investors , Lenders , Libor , MD&A Statements , Mortgage Lenders , Mutual Funds , New Guidance , No-Action Letters , No-Action Relief , Notice of Proposed Rulemaking (NOPR) , Policy Statement , Proposed Amendments , Proposed Rules , Public Comment , Publicly-Traded Companies , Regulation S-K , Reporting Requirements , Secured Overnight Funding Rate (SOFR) , Securities and Exchange Commission (SEC) , Vendors , Volcker Rule

Alexander Callen

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