The Office of the Comptroller of the Currency (OCC) released an Advance Notice of Proposed Rulemaking (ANPR) on June 4, 2020, announcing a review of 12 CFR part 7, subpart E related to national bank electronic activities and...more
Developing Contingency Plans: The NYDFS Mandate on Licensed Virtual Currency Businesses -
The events surrounding COVID-19 have increased the use of fintech products, both out of necessity and convenience. Shelter-in-place...more
4/17/2020
/ Banking Sector ,
Chief Information Security Officer (CISO) ,
Compliance ,
Confidential Information ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Cybersecurity Framework ,
Data Protection ,
Digital Assets ,
Disclosure Requirements ,
Financial Institutions ,
Financial Services Industry ,
Finetech ,
Information Technology ,
Insurance Industry ,
Notice Requirements ,
NYDFS ,
Payment Systems ,
Personally Identifiable Information ,
Popular ,
Risk Assessment ,
Risk Management ,
Third-Party Service Provider ,
World Health Organization
The events surrounding COVID-19 have increased the use of fintech products, both out of necessity and convenience. Shelter-in-place directives have moved customers towards fintech solutions, as have concerns aligned with the...more
4/2/2020
/ Banks ,
Business Losses ,
Business Plans ,
Contingency Plans ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Financial Stimulus ,
FinTech ,
Payment Systems ,
Risk Assessment ,
World Health Organization
While SEC FinHub’s new framework announced last week for identifying crypto-securities suggests continued resistance for those using digital assets to access capital markets, an SEC no-action letter issued the same day to...more
4/11/2019
/ Blockchain ,
Capital Markets ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
Howey ,
Initial Coin Offering (ICOs) ,
No-Action Letters ,
Offerings ,
Popular ,
Regulation A ,
Regulation D ,
Regulation S ,
Regulatory Agenda ,
Securities ,
Securities and Exchange Commission (SEC) ,
Token Sales
In the ancient parable of the Blind Men and the Elephant, a group of blind men who had never come across an elephant before were asked to describe it. Each blind man felt a different part of the elephant’s body, but only one...more
On September 30, 2018, California Governor Jerry Brown signed into law Senate Bill No. 826 (SB 826). SB 826 adds Sections 301.3 and 2115.5 to the California Corporations Code to require that a publicly held company with a...more
EXECUTIVE SUMMARY –
Following testimony February 6th before the U.S. Senate, as well as a series of recent enforcement actions, it is clear that both the SEC and CFTC are picking up steam in their efforts to command a...more