On July 27, 2023, the Board of Governors of the Federal Reserve System (FRB), the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, FBAs) issued their long-awaited...more
New circular warns that unilaterally reopening closed accounts can constitute an unfair practice -
On May 10, 2023, the Consumer Financial Protection Bureau ("CFPB" or the "Bureau") published guidance warning banks that...more
On April 21, 2023, the Financial Stability Oversight Council ("FSOC") issued two important proposals regarding the designation of a nonbank financial firm as a systemically important financial institution ("nonbank SIFI")...more
Is my money safe? It's a question that we haven't heard very much in over twelve years.
Most businesses and people have no experience with troubled banks and potential bank failures....more
As described in DWT's October 2021 post, the Corporate Transparency Act ("CTA"), enacted as part of the Anti-Money Laundering Act of 2020, establishes beneficial ownership reporting requirements for a broad range of entities...more
Key developments in the United States over the past several months have kicked the digital currency transformation discussion into high gear. After the President’s Working Group on Financial Markets’ November 2021 Report on...more
Our team is pleased to announce an important publication on crypto developments and future stablecoin regulation in the United States. Here we provide a brief overview of stablecoins, outline various risks and policy concerns...more
In July, we discussed the federal banking agencies' proposal to harmonize their respective risk management guidance. At the time, we highlighted three passages from the proposal that relate to the due diligence banking...more
Last week, the federal banking agencies—Federal Reserve Board (Board), Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC)—issued proposed interagency guidance ("Proposal") on...more
Update: On May 17, 2021, the agencies extended the deadline for comments from June 1, 2021, to July 1, 2021. The text of this post has been updated accordingly....more
The federal financial institutions regulatory agencies collectively issued a Request for Information and Comment (RFI) on March 31, 2021, to better understand how artificial intelligence (AI) and machine learning (ML) are...more
Less than one month ago, Brian Brooks assumed the position of Acting Comptroller of the Office of the Comptroller of the Currency (OCC). Upon taking the position, Acting Comptroller Brooks released a statement outlining goals...more
The COVID-19 pandemic provides a stark reminder about the importance of responding to rapid changes in a timely and expeditious manner. In the span of a few weeks, unemployment levels have skyrocketed to unprecedented levels,...more
In connection with the ongoing efforts of various federal agencies to implement and execute the Paycheck Protection Program (PPP) established pursuant to provisions of the Coronavirus Aid, Relief, and Economic Security Act...more
Update April 3: The Small Business Administration (SBA) issued an Interim Final Rule (IFR) earlier today implementing the Paycheck Protection Program (PPP). The IFR has a 30 day comment period (from the date of publication in...more
The recently enacted CARES Act includes an unprecedented financial stimulus package focused squarely on small and medium-sized businesses, most of which have been significantly impacted from the economic fallout of COVID-19....more
On October 21, 2019, the District Court for the Southern District of New York entered a final judgment in favor of the New York State Department of Financial Services (NYDFS), blocking the Office of the Comptroller of the...more
There has been an unprecedented wave of consolidation in the U.S. payment processing industry this year, with two major core processors acquiring the two largest merchant acquirers, and two of the largest remaining payment...more