During hearings before the House of Representatives on June 30, 2020, Representative Steve Stivers (R-OH), asked Treasury Secretary Mnuchin about financial institution’s payment of agent fees as part of the Paycheck...more
The Office of the Comptroller of the Currency (“OCC”) adopted a final rule on June 2, 2020 that clarifies that when a bank transfers a loan, the interest permissible before the transfer continues to be permissible after the...more
Join Brad Rustin, Craig Nazzaro, and Mark Miller as they cover the shift in customer needs and experience and the impact this shift has on your BSA/AML/KYC concerns, CRA program, and fintech partnership risks. They will also...more
6/5/2020
/ Banking Sector ,
BSA/AML ,
Coronavirus/COVID-19 ,
CRA ,
Financial Services Industry ,
FinTech ,
Fintech Charter ,
Know Your Customers ,
Risk Management ,
Sandbox ,
Webinars
(For Information on PPP forgiveness that is written specifically for borrowers, please find our borrower’s guide and checklist). After much anticipation, the Small Business Administration (“SBA”) issued a formal Paycheck...more
The federal banking agencies recently issued principles to encourage financial institutions to offer small-dollar loans in a responsible manner (the “Small-Dollar Loan Principles”). This interagency guidance clarifies...more
The Small Business Administration (“SBA”) recently issued a formal Paycheck Protection Program (“PPP”) Loan Forgiveness Application. We will highlight a number of key elements of the application. Additionally, we will review...more
5/22/2020
/ CARES Act ,
Compliance ,
Coronavirus/COVID-19 ,
Financial Services Industry ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
SBA ,
SBA Lending Programs ,
Secretary of the Treasury ,
Small Business ,
Webinars
The SBA issued an additional FAQ #46, providing guidance on how it will review the required good faith certification that current economic uncertainty make the PPP loan necessary to support ongoing operations, which we refer...more
In response to the economic crisis caused by the COVID-19 pandemic, the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), was signed into law and dedicated $349 billion to the Paycheck Protection Program...more
The Office of the Comptroller of the Currency (OCC) released “OCC Bulletin 2020-44” which encourages institutions to “prudently document their implementation and lending decisions” under the Small Business Administration's...more
As all financial institutions are beginning to realize, the rapidly evolving regulatory landscape surrounding the Paycheck Protection Program (“PPP”) is presenting several unintended consequences to both financial...more
As every financial institution likely knows, last week brought the implementation of the Paycheck Protection Program (“PPP”) under the CARES Act. However, with the launch of the program by a number of financial institutions,...more
Last week the Department of Justice (DOJ) announced criminal charges against U.S. Bancorp “consisting of two felony violations of the Bank Secrecy Act (‘BSA’) by its subsidiary, U.S. Bank National Association (the ‘Bank’),...more
Following nearly three years of litigation, the D.C. Circuit handed down a 7 to 3 ruling in PHH Corp. v. Consumer Financial Protection Bureau. The two hundred fifty page opinion addressed not only the constitutional...more
2/8/2018
/ Administrative Proceedings ,
Constitutional Challenges ,
Consumer Financial Protection Bureau (CFPB) ,
Kickbacks ,
Mortgage Insurance ,
Mortgages ,
PHH Corp. v CFPB ,
Reinsurance ,
Removal For-Cause ,
RESPA ,
Single Director
Seven states have agreed to a multi-state compact standardizing key aspects of money services business (MSB) licensing. As of today, Georgia, Illinois, Kansas, Massachusetts, Tennessee, Texas, and Washington have joined into...more
On Monday, the Securities and Exchange Commission (SEC) announced it had obtained a court order suspending AriseBank’s (Arise) initial coin offering (ICO) whose public sale began in late December. According to the SEC, Arise...more