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Federal Regulators Issue Updated Guidance on Liquidity Risks and Contingency Planning

On July 28, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the National Credit Union Administration (the “NCUA”) and the Office of the...more

Federal Regulators Issue Notice of Proposed Rulemaking Revising Capital Requirements for Large Banks and Banks with Significant...

On July 27, 2023, in an effort to bolster the resilience of the U.S. banking system in the aftermath of recent bank failures and to promote consistency with international banking capital standards, the Federal Deposit...more

UPDATE: U.S. House of Representatives Seeks to Amend the CARES Act to Provide Borrower’s Relief under the PPP

On May 28, 2020, the U.S. House of Representatives passed legislation that, if adopted by the Senate and signed into law by the President, would provide considerable relief to borrowers under the Paycheck Protection Program...more

SBA Announces Procedure for PPP Lenders to Collect Loan Processing Fees

On May 21, 2020, the U.S. Small Business Administration (“SBA”) released a notice informing lenders of how they may collect loan processing fees for eligible loans issued under the Paycheck Protection Program...more

Paycheck Protection Program Loans May Be Excluded from a Bank’s Regulatory Capital Ratios

On April 9, 2020, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), and the Office of the Comptroller of the Currency (collectively, the “federal banking...more

Temporary Regulatory Relief: Community Bank Leverage Ratio Set At 8%

On April 6, 2020, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Board of Governors of the Federal Reserve System (collectively, the “federal banking agencies”) announced the...more

The CARES Act: What Does It Mean for Financial Institutions?

On March 27, 2020, the President signed into law the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”). While the CARES Act contains a variety of provisions, including, among other things, unemployment...more

Federal Reserve Suspends Regulatory Examination Activity for Banks with Total Consolidated Assets Under $100 Billion

On March 24, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued a statement on its supervisory activities (“Statement”) during the unprecedented COVID-19 pandemic. As part of that...more

Coronavirus Update: Strategies and Considerations for Financial Institutions

Over the past two weeks, we have received numerous inquiries from financial institutions on what actions should be taken or considered to address the COVID-19/Coronavirus pandemic. While every bank is different and the...more

Coronavirus: Considerations for Financial Institutions

Over the past two weeks, the international markets have been roiling under news that the COVID-19 virus, commonly referred to as the coronavirus, may be spreading. The Board of Governors of the Federal Reserve System (the...more

Federal Banking Agencies Issue Community Bank Leverage Ratio Compliance Guide

On October 29, 2019, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the “Federal Banking Agencies”) issued a joint press...more

CECL Implementation Delayed for Qualifying Entities

On October 16, 2019, the Financial Accounting Standards Board (“FASB”) extended the implementation deadline for the current expected credit loss standard (“CECL”) for qualifying entities. The new implementation deadlines are...more

FDIC Finalizes Rule to Simplify Capital Calculations for Community Banks

On September 17, 2019, the Federal Deposit Insurance Corporation (the “FDIC”) passed a final rule providing qualifying community banking organizations the ability to opt-in to a new community bank leverage ratio (“CBLR”)...more

SEC Proposes Rules to Update Disclosures for Public Bank Holding Companies, Banks, Savings and Loan Holding Companies and Savings...

On September 17, 2019, the Securities and Exchange Commission (the “SEC”) proposed rules that would update the statistical disclosures currently required by Industry Guide 3, Statistical Disclosure by Bank Holding Companies...more

Volcker Rule: Community Bank Exemption

On July 9, 2019, the Board of Governors of the Federal Reserve System (the “FRB”), U.S. Commodity Futures Trading Commission, Federal Deposit Insurance Corporation (the “FDIC”), Office of the Comptroller of the Currency (the...more

A Small Win: Illinois to Phase-Out Franchise Tax

On June 5, 2019, Illinois Governor J.B. Pritzker signed a $40 billion state budget bill into law. Among the various provisions included in the over 300 page budget is a provision providing for the phase-out of Illinois’...more

Update: When Are Section 19 Application Required?

On November 1, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) issued modifications to its Statement of Policy (“SOP”) for applications made under Section 19 of the Federal Deposit Insurance Act (“FDIA”). The...more

Regulatory Relief Continues: Federal Banking Agencies Propose New Capital Relief Rules for Large Banking Organizations

On October 31, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Office of the Comptroller of the Currency (the “OCC”) and the Federal Deposit Insurance Corporation (the “FDIC”) issued a...more

Regulatory Alert: Federal Regulators Issues New FAQs on Appraisal and Evaluation

On October 16, 2018, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Board of Governors of the Federal Reserve System (the “Agencies”) issued the Frequently Asked Questions on...more

Bringing a Level of Clarity to the Interagency Biographical and Financial Report

On July 11, 2018, the Office of the Comptroller of the Currency (“OCC”), the Federal Deposit Insurance Corporation (“FDIC”) and the Board of Governors of the Federal Reserve System (“FRB”) (the OCC, FRB and FDIC are...more

Update: Regulatory Relief Passed by Congress

On May 22, 2018, the House of Representatives passed the bipartisan Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) (the “Consumer Protection Act”), which had been previously passed by the Senate. The...more

BSA/AML ALERT: FinCEN Grants a 90-Day Exemption from the Beneficial Ownership Rule for Certain Financial Product Renewals and...

On May 11, 2018, compliance with the beneficial ownership rule became mandatory. In accordance with the rule, a covered financial institution must verify, at the time a new account is opened, the beneficial owners opening the...more

BSA/AML Alert: The Beneficial Ownership Rule Becomes Effective Today

On May 11, 2018, the beneficial ownership rule became fully effective. While the rule was finalized on July 16, 2016, compliance was not mandatory until May 11, 2018. The delay in implementation was to permit covered...more

IP Alert: Check-Processing Servicers Beware!

After a 10 day jury trial, a jury found U.S. Bancorp liable for almost $3.3 million in damages for infringing upon a patent covering check-processing technology owned by Solutran, Inc. (”Solutran”). Solutran’s U.S. Patent No....more

How to Evaluate Cyber Insurance Options?

On April 10, 2018, the Federal Financial Institutions Examination Council (the “FFIEC”), an interagency body composed of the Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau, Federal...more

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