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The Bank Preemption Ripple Effects After Cantero, Flagstar

On May 30, the U.S. Supreme Court issued a unanimous decision in Cantero v. Bank of America, vacating and remanding a decision by the Second Circuit that concluded that the federally authorized powers of national banks under...more

The Drawbacks Of Banking Regulators' Merger Review Plans

The Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency recently announced proposals to update their approaches to evaluating bank mergers and other business combinations under the Bank Merger...more

A Look At The Feds' Extraordinary Reaction To SVB Collapse

On Sunday evening, the U.S. Department of the Treasury, Federal Reserve, and the Federal Deposit Insurance Corporation announced measures to (1) prevent losses to all depositors — including all uninsured depositors — after...more

Treasury, Federal Reserve, and FDIC Take Actions to Protect Bank Depositors and Support Bank Liquidity to Conduct Operations

On Sunday evening, the Department of the Treasury (Treasury), Federal Reserve, and the Federal Deposit Insurance Corporation (FDIC) announced measures to (1) prevent losses to all depositors—including all uninsured...more

Flurry of Announcements by the Federal Reserve on Crypto Activities

A flurry of activity on January 27 signaled continued skepticism from the Federal Reserve of crypto-asset-related activities generally and open, public or decentralized networks in particular....more

Federal Financial Regulators Propose Requiring Banks Report Cyber Incidents Within 36 Hours

On December 17, 2020, the Office of the Comptroller of the Currency, Treasury (OCC); the Federal Reserve; and the Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking that would require...more

FinCEN Releases Frequently Asked Questions Regarding Customer Due Diligence and Beneficial Ownership Requirements

Last week the Financial Crimes Enforcement Network (FinCEN) issued much-anticipated Frequently Asked Questions (FAQs) that provide additional guidance to financial institutions relating to the implementation of the new...more

NYDFS Proposes to Require Chief Compliance Officers to Certify Effectiveness of AML and Sanctions Programs

The New York Department of Financial Services has issued a proposed regulation that sets forth minimum requirements for anti-money laundering transaction monitoring systems and watch list filtering systems. The proposed...more

FinCEN Proposes AML Requirements for Registered Investment Advisers

The Financial Crimes Enforcement Network (FinCEN) has proposed long-expected regulations that would extend anti-money laundering (AML) requirements to federally registered investment advisers (RIA). The August 25, 2015...more

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