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
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
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