In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve) expanded access to its Paycheck Protection Program Liquidity Facility (PPPLF) to non-bank lenders and expanded the collateral eligible to...more
5/7/2020
/ Banking Regulators ,
Banking Sector ,
Borrowers ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Enforcement Actions ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Forbearance Agreements ,
Foreclosure ,
Lenders ,
Liquidity Coverage Ratio ,
Loan Forgiveness ,
Main Street Lending Programs ,
Money Market Mutual Fund Liquidity Facility (MMLF) ,
Mortgage Lenders ,
Mortgages ,
Nasdaq ,
New Guidance ,
Non-Bank Lenders ,
Paycheck Protection Program (PPP) ,
Paycheck Protection Program Lending Facility (PPPL Facility) ,
Price Gouging ,
Risk Management ,
SBA ,
Securities and Exchange Commission (SEC) ,
Shareholder Approval
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule that would establish a revised framework for the fair value determination for purposes of the Investment Company Act of 1940 and have...more
4/30/2020
/ Banking Sector ,
Best Practices ,
Board of Directors ,
Borrowers ,
Class Action ,
Consumer Financial Protection Bureau (CFPB) ,
Contact Tracing ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Enforcement Actions ,
Eviction ,
Fair Access to Credit ,
Fair Lending ,
Fair Valuation ,
Federal Reserve ,
FHFA ,
FHLB ,
Financial Institutions ,
Financial Services Industry ,
Foreclosure ,
Government Investigations ,
Investment Companies ,
Investment Company Act of 1940 ,
Lenders ,
Mortgage Servicers ,
New Guidance ,
Paycheck Protection Program (PPP) ,
Proposed Rules ,
SBA ,
Securities and Exchange Commission (SEC) ,
Small Business ,
Small Business Loans
In this Issue: Senate Votes to Expand Paycheck Protection Program; FHFA (Finally) Addresses Liquidity Concerns for Mortgage Servicers. Yesterday, the U.S. Senate unanimously passed legislation providing $484 billion in...more
4/24/2020
/ Banking Sector ,
Borrower Protection Programs ,
Borrowers ,
BSA/AML ,
CARES Act ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Fannie Mae ,
Federal Funding ,
Federal Reserve ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Financial Stimulus ,
Freddie Mac ,
HMDA ,
Legislative Agendas ,
Lenders ,
Liquidity ,
Main Street Lending Programs ,
Mortgage Servicers ,
Paycheck Protection Program (PPP) ,
Regulatory Requirements ,
SBA ,
SBA Lending Programs ,
Small Business ,
Startups
Priming the Pump. As the COVID-19 outbreak continues, the Board of Governors of the Federal Reserve System (Federal Reserve), consistent with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), took additional...more
4/16/2020
/ Banking Sector ,
Business Development Companies ,
Capital Rules ,
CARES Act ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Enforcement Actions ,
Federal Loans ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Financial Stimulus ,
Interim Final Rules (IFR) ,
Investment Management ,
Main Street Lending Programs ,
New Guidance ,
Paycheck Protection Program (PPP) ,
Proxy Materials ,
Real Estate Transactions ,
Relief Measures ,
Remittance Transfer Rule ,
SBA ,
Securities and Exchange Commission (SEC) ,
Small Business ,
State and Local Government ,
U.S. Treasury
Paycheck Protection Problems. In last week’s Roundup, we discussed the initial guidance issued by the U.S. Department of the Treasury (Treasury) and the Small Business Administration (SBA) on the implementation of the...more
4/10/2020
/ Banking Sector ,
Broker-Dealer ,
CARES Act ,
Coronavirus/COVID-19 ,
Enforcement Actions ,
Federal Loans ,
Federal Reserve ,
Financial Services Industry ,
Financial Stimulus ,
Form CRS ,
Interim Final Rules (IFR) ,
Investment Adviser ,
Investment Management ,
Lenders ,
OCIE ,
Paycheck Protection Program (PPP) ,
Regulation Best Interest ,
Regulatory Requirements ,
Relief Measures ,
Risk Alert ,
SBA ,
SBA Lending Programs ,
Securities and Exchange Commission (SEC) ,
Small Business ,
U.S. Treasury
In This Issue. The ongoing global outbreak of the coronavirus (COVID-19) continues to grow in scale and scope, creating public health and humanitarian challenges worldwide. Global economies are also being impacted. Federal...more
3/12/2020
/ Banking Sector ,
Banks ,
Business Continuity Plans ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Crisis Management ,
Disclosure Requirements ,
Exemptive Relief ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Foreign Banks ,
Foreign Investment ,
Infectious Diseases ,
Investment Management ,
New Guidance ,
OCC ,
Proposed Rules ,
Public Health ,
Risk Management ,
Securities and Exchange Commission (SEC)
In This Issue. Federal banking agencies finalized an Interagency Policy Statement on Allowance for Credit Losses, which is intended to promote consistency in the interpretation and application of the current expected credit...more
3/6/2020
/ Amended Rules ,
Banking Sector ,
CBLR ,
Consumer Financial Protection Bureau (CFPB) ,
Creditors ,
Disclosure Requirements ,
Enforcement Actions ,
Financial Services Industry ,
Lenders ,
Policy Statement ,
Securities and Exchange Commission (SEC) ,
TILA-RESPA Integrated Disclosure Rule (TRID)
The community bank leverage ratio framework (CBLR Framework) is available for use beginning with the March 31, 2020 Call Report and Form FR Y-9C (consolidated financial statements for holding companies). A qualifying...more
In This Issue. The Federal Deposit Insurance Corporation (FDIC) published new procedures for federal deposit insurance applications from applicants that are not traditional community banks; federal banking regulators released...more
2/13/2020
/ Applications ,
Banking Sector ,
Banks ,
BlackRock ,
Borrowers ,
Community Banks ,
Consumer Financial Protection Bureau (CFPB) ,
Deposit Insurance ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Fraud ,
Financial Services Industry ,
Insurance Industry ,
Interest Rates ,
Investment Funds ,
Investors ,
Lenders ,
New Guidance ,
Non-Bank Lenders ,
Payday Loans ,
Publicly-Traded Companies ,
State Attorneys General ,
State Street ,
Stress Tests ,
Truth in Lending Act (TILA)
In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more
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
On January 30, 2020, the Board of Governors of the Federal Reserve System (Federal Reserve) issued a final rule (Rule) that revises the Federal Reserve’s regulations related to determinations of whether a first company (an...more
2/5/2020
/ Bank Holding Company Act ,
Banks ,
Board of Directors ,
Board of Governors ,
CBCA ,
CEOs ,
Controlling Influence Test ,
Controlling Stockholders ,
Divestiture ,
Equity Investors ,
Established Business Relationship ,
Federal Reserve ,
Fiduciary Exception ,
Final Rules ,
Financial Statements ,
GAAP ,
HOLA ,
Investment Adviser ,
Investment Companies ,
Investment Funds ,
Investors ,
Management Agreements ,
Non-Controlling Interests ,
Private Equity ,
Proxy Solicitations ,
Publicly-Traded Companies ,
Senior Managers ,
Voting Securities
In This Issue. The Consumer Financial Protection Bureau (CFPB) released a policy statement outlining framework that the CFPB will immediately begin to apply in matters of supervision and enforcement regarding the “abusive”...more
1/31/2020
/ Abusive Acts ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
Digital Currency ,
FDIC ,
FIRRMA ,
Foreign Investment ,
ISDA ,
Libor ,
MD&A Statements ,
OCC ,
OCIE ,
Securities and Exchange Commission (SEC) ,
UK
In This Issue. The Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) proposed the first substantive amendments to regulations implementing the Community Reinvestment Act in...more
In This Issue. The Office of the Comptroller of the Currency (OCC) highlighted the key risks facing the federal banking system in its Semiannual Risk Perspective for Fall 2019; the Financial Stability Oversight Council (FSOC)...more
In This Issue. The Securities and Exchange Commission (SEC) proposed a rule that would permit funds to enter into derivative and certain other transactions, notwithstanding leverage restrictions under the Investment Company...more
In This Issue. The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Federal Reserve Board), and the Federal Deposit Insurance Corporation (FDIC) issued two final rules —...more
Editor's Note -
In This Issue. The U.S. Securities and Exchange Commission’s (SEC) Division of Investment Management staff announced plans to seek industry input on custodial practices relating to trading that is not...more
3/21/2019
/ CFTC ,
Disclosure Requirements ,
FDCPA ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
Investment Adviser ,
Investment Company Act of 1940 ,
Securities and Exchange Commission (SEC) ,
TCPA ,
UK Brexit
Editor's Note -
Busy Week for the Fed. The Board of Governors of the Federal Reserve System (Federal Reserve) was busy this past week, announcing that it would limit use of the “qualitative objection” in its Comprehensive...more
3/14/2019
/ CCAR ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Department of Labor (DOL) ,
FFIEC ,
Financial Services Industry ,
FSOC ,
Minimum Salary ,
Over-Time ,
Regulation D ,
Servicemembers Civil Relief Act (SCRA) ,
Wage and Hour
Editor's Note -
Good News, Bad News. Key developments in federal securities laws have recently brought both good news and bad news for current and prospective public companies. First, the Securities and Exchange Commission...more
Editor's Note -
A Big Deal. On February 7, BB&T and SunTrust announced a “merger of equals” in an all-stock transaction valued at $66 billion. The transaction is the largest U.S. bank merger in over a decade and will...more
Editor's Note -
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve) released 2019 stress test scenarios and exempted less complex banks with between $100 billion and $250 billion in assets...more
2/7/2019
/ Banks ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Employee Retirement Income Security Act (ERISA) ,
FDIC ,
Federal Reserve ,
Financial Services Industry ,
Investment Management ,
OCC ,
Payday Loans ,
Securities and Exchange Commission (SEC) ,
Stress Tests ,
Subsidiaries ,
TILA-RESPA Integrated Disclosure Rule (TRID)
Editor's Note -
The Legacy of the Government Shutdown Lives On. The federal government shutdown is finally over, at least temporarily. However, its legacy lives on as federal financial regulators must now deal with the...more
Editor's Note -
When will the government shutdown end? The government shutdown has forced many federal agencies, including those mentioned in the articles below, to operate in accordance with the agency's emergency plan for...more
1/10/2019
/ BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Act ,
FDIC ,
Financial Services Industry ,
HMDA ,
Interest Rates ,
OCC ,
OCIE ,
Popular ,
Securities and Exchange Commission (SEC) ,
Stress Tests
Editor's Note -
In This Issue. The Securities and Exchange Commission (SEC) adopted rules and amendments designed to promote research on mutual funds, exchange-traded funds (ETFs), registered closed-end funds, business...more
12/7/2018
/ Banking Sector ,
Banks ,
Carlton & Harris Chiropractic Inc v PDR Network LLC ,
Data Protection ,
EU ,
Financial Services Industry ,
General Data Protection Regulation (GDPR) ,
Institutional Shareholder Services (ISS) ,
Investment Funds ,
OCC ,
Securities and Exchange Commission (SEC) ,
Shareholders ,
TCPA
In This Issue. Federal banking regulators proposed the long-awaited “community bank leverage ratio,” which would exempt community banks with a leverage ratio of at least 9% from Basel III capital requirements; the Federal...more
11/29/2018
/ Antitrust Division ,
ATDS ,
Banking Sector ,
Banks ,
Basel III ,
Blockchain ,
CFIUS ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
FASB ,
FDIC ,
FFIEC ,
FHFA ,
NYSE ,
Real Estate Development ,
Regulation CC ,
Regulation J ,
Regulation M ,
Regulation Z ,
Securities and Exchange Commission (SEC) ,
Servicemembers Civil Relief Act (SCRA) ,
Smaller Reporting Companies