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FinCEN Finalizes Rule to Compel Reporting of Individuals and Beneficial Ownership of Entities Involved in Specified Transfers of...

FINCEN’s final rule (RRE Rule), effective December 1, 2025, will require disclosure of the transferor and transferee(s) and the individuals and the beneficial owners of entities involved as transferee in the transfer of...more

U.S. Financial Regulators Continue Focus on Bank-Fintech Partnerships through Guidance and Request for Information

On July 25, 2024, the Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a joint statement describing potential...more

Operational Resilience Requirements May Be Coming for Large U.S. Banks Soon

On March 12, 2024, Acting Comptroller of the Currency Michael Hsu indicated in a speech that regulations may soon be forthcoming that would be designed to bolster larger depository institutions’ ability to withstand...more

CFPB Finalizes Small Business Lending Data Rule

A far-reaching new federal regulation will for the first time require small business lenders to collect detailed data about applications and originations, and report that data to the Consumer Financial Protection Bureau...more

U.S. Department of the Treasury Confronts the Risks to the Financial Sector Associated with Cloud Computing

On February 8, 2023, the U.S. Department of the Treasury released a report citing its “findings on the current state of cloud adoption in the sector, including potential benefits and challenges associated with increased...more

New York Finalizes Disclosure Requirements for Commercial Financing Transactions

New York has joined California and several other states in finalizing regulations requiring consumer-style disclosures for broad categories of commercial financing transactions....more

What to Expect from the New York Department of Financial Services in 2023

In 2023, the NYDFS is poised to finalize several significant new regulations and will likely continue its aggressive cybersecurity, anti-money laundering (AML) and consumer protection enforcement. The New York Department of...more

Federal Banking Regulators Propose Overhaul of Community Reinvestment Act

Regulators took a first step toward modernizing CRA regulations with a joint Notice of Proposed Rulemaking. The proposed rule would add more standardized metrics for regulators’ CRA examinations and more clearly delineate...more

New York to Require Crypto Companies to Pay Assessment Fees

New York will for the first time require companies that hold a BitLicense to pay annual assessment fees. The new fee will increase the already high cost of obtaining a BitLicense and operating a crypto business in New...more

Federal Regulators Adopt New Computer-Security Incident Notification Requirements for Banks and Service Providers

In response to increasingly frequent and sophisticated cybersecurity attacks on banks and bank service providers, the federal prudential banking regulators—the Office of the Comptroller of the Currency (OCC), the Board of...more

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