On September 15, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its first “Gap Rule” enforcement action in a Consent Order with Bancrédito International Bank and Trust...more
9/26/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bribery ,
Consent Order ,
Enforcement Authority ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Puerto Rico ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding ,
U.S. Treasury
UPDATE (3/20 PM):
Developments Related to Flagstar Bank, SVBB, SVB Financial Group, Credit Suisse, and First Republic Bank-
On March 19, 2023, the FDIC announced that the agency has entered into a purchase and...more
3/22/2023
/ Banks ,
Borrowers ,
Deposit Accounts ,
FDIC ,
Federal Reserve ,
Investors ,
Liquidity ,
Receivership ,
Swiss Banks ,
Systemic Risk Buffer ,
U.S. Treasury
UPDATE (3/12 PM):
U.S. Treasury Uses Systemic Risk Exception to Protect Depositors of Failed Banks and the Federal Reserve Board Establishes New Emergency Facility.
Following the failure of Silicon Valley Bank (SVB) on...more
3/13/2023
/ Bank Deposits ,
Board of Governors ,
FDIA ,
FDIC ,
Federal Reserve ,
Line of Credit ,
Loans ,
Popular ,
Receivership ,
U.S. Treasury ,
Uninsured Deposits ,
Wages
On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) announced an Advance Notice of Proposed Rulemaking (ANPRM) to solicit comments in preparing a proposed rule that would increase transparency in the U.S....more
12/16/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Corruption ,
Financial Action Task Force ,
FinCEN ,
GTO ,
Popular ,
Real Estate Market ,
SAR ,
Title Insurance ,
Transaction Reporting ,
U.S. Treasury
On April 30, 2020, the Board of Governors of the Federal Reserve System (“FRB”) announced an expansion of the Main Street Lending Program (“MSLP”) and clarified certain aspects of the program through publication of a list of...more
EDITOR’S NOTE -
So much for the lazy days of summer. It’s been a busy couple of months on both coasts. In a case of déjà vu all over again, a New York federal court found that the CFPB structure is unconstitutional and that...more
9/12/2018
/ Arbitration ,
BSA/AML ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Financial Services Industry ,
FinTech ,
Fixing America’s Surface Transportation Act (FAST Act) ,
Mortgages ,
OCC ,
RMBS ,
TCPA ,
U.S. Treasury ,
Volcker Rule
EDITOR’S NOTE -
The holidays came early for the financial services industry. First, the Senate voted to repeal the CFPB’s rule banning class waivers in arbitration agreements in consumer financial contracts. Then,...more
12/12/2017
/ Arbitration ,
Biometric Information Privacy Act ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Debt ,
ECOA ,
FDIC ,
FinCEN ,
HMDA ,
NYDFS ,
OCC ,
Payday Loans ,
TCPA ,
Trump Administration ,
U.S. Treasury ,
Virtual Currency
EDITOR’S NOTE -
Through hurricanes, wild fires, the publication of Hillary Clinton’s book, the birth of Amal and George Clooney’s twins, and the Dodgers’ historic losing streak, Director Richard Cordray and the CFPB’s...more
9/21/2017
/ Arbitration ,
BSA/AML ,
Credit Repair Services ,
Data Breach ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
False Claims Act (FCA) ,
FCC ,
FinTech ,
OCC ,
Ransomware ,
RESPA ,
Spokeo v Robins ,
Standing ,
Stress Tests ,
TCPA ,
U.S. Treasury ,
Volcker Rule