On May 19, FinCEN and BIS issued an alert urging financial institutions to watch for attempts to evade export controls imposed on Russia. The alert focuses on ongoing federal initiatives to limit Russian access to technology...more
5/26/2023
/ Bureau of Industry and Security (BIS) ,
CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Derivatives Clearing Organizations ,
Economic Sanctions ,
Evasion ,
Export Controls ,
Financial Institutions ,
FinCEN ,
FinTech ,
Freddie Mac ,
Interest Rates ,
Registration Requirement ,
Russia ,
Safeguards Rule ,
Securities and Exchange Commission (SEC) ,
UDAAP
Regulatory Developments -
FinCEN Issues Initial Beneficial Ownership Information Reporting Guidance -
On March 24, FinCEN published guidance materials for the new beneficial ownership reporting requirements taking...more
4/17/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Commercial Loans ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Transparency Act ,
Credit Cards ,
Financial Institutions ,
FinCEN ,
Preemption ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Truth in Lending Act (TILA)
Regulatory Developments -
FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers -
On January 17, FinCEN proposed a form of report to collect beneficial...more
1/27/2023
/ Beneficial Owner ,
Broker-Dealer ,
Civil Monetary Penalty ,
Climate Change ,
Consumer Financial Protection Bureau (CFPB) ,
Examination Priorities ,
Federal Reserve ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
FinCEN ,
Mortgage Servicers ,
New Guidance ,
Reporting Requirements ,
Risk Assessment ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Transfer on Death Deed (TOD)
Regulatory Developments -
FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards -
On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more
1/18/2023
/ 10b5-1 Plans ,
Anti-Money Laundering ,
Beneficial Owner ,
Community Reinvestment Act ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Transparency Act ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
FinCEN ,
Interest Rates ,
Libor ,
New Guidance ,
Nonbank Firms ,
NPRM ,
Regulation O ,
Regulation Z ,
Relief Measures ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Small Banks ,
Threshold Requirements ,
Time Extensions
In This Issue. The Financial Crimes Enforcement Network (FinCEN) is urging financial institutions to focus their efforts on detecting the proceeds of foreign public corruption; the Financial Industry Regulatory Authority...more
4/22/2022
/ Annual Reports ,
Bribery ,
Climate Change ,
Corruption ,
Embezzlement ,
Environmental Social & Governance (ESG) ,
ETFs ,
Extortion ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Statements ,
FinCEN ,
Greenhouse Gas Emissions ,
Investors ,
Misappropriation ,
Money Laundering ,
Proposed Amendments ,
Proposed Rules ,
Public Corruption ,
Publicly-Traded Companies ,
Registration Statement ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more
3/14/2022
/ Banking Sector ,
Belarus Sanctions ,
Beneficial Owner ,
Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Digital Assets ,
Economic Sanctions ,
Executive Orders ,
FATF ,
FDIC ,
Financial Action Task Force ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investors ,
Money Laundering ,
OCC ,
Risk Assessment ,
Risk Management ,
Russia ,
Shell Corporations ,
Terrorist Financing ,
U.S. Treasury ,
Virtual Currency
In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more
2/18/2022
/ Augmented Reality ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
Derivatives ,
FDIC ,
Federal Reserve ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment Firms ,
Investors ,
OCC ,
OMB ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Reporting Requirements ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Stress Tests ,
Virtual Reality ,
Whistleblower Protection Policies ,
Whistleblowers
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more
2/11/2022
/ Appraisal ,
Banking Sector ,
Beneficial Owner ,
Borrowers ,
Comment Period ,
Community Development ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Transparency Act ,
Cyber Attacks ,
Cyber Threats ,
Cybersecurity ,
Dodd-Frank ,
Fair Lending ,
FDIC ,
Federal Reserve ,
Federal Savings Associations ,
Financial Services Industry ,
FinCEN ,
FinTech ,
Investment Adviser ,
Investment Companies ,
Lenders ,
New Rules ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Policies and Procedures ,
Private Funds ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Reporting Requirements ,
Risk Management ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
State Savings Associations ,
Valid When Made Doctrine
In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more
1/28/2022
/ Borrowers ,
Broker-Dealer ,
Civil Monetary Penalty ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Cross-Border ,
Deposit Insurance ,
Disclosure Requirements ,
Division of Investment Management ,
European Securities and Markets Authority (ESMA) ,
Examination Procedures ,
FDIC ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Fund Distribution ,
Inflation Adjustments ,
Investors ,
Irrevocable Trusts ,
Lenders ,
Marketing ,
Mortgage Servicers ,
New Rules ,
Notice of Proposed Rulemaking (NOPR) ,
Pilot Programs ,
Proposed Rules ,
Public Comment ,
Reporting Requirements ,
Revocable Trusts ,
Securities and Exchange Commission (SEC) ,
Student Loans ,
Suspicious Activity Reports (SARs)
In This Issue. The Federal Deposit Insurance Corporation (FDIC), the FDIC Tech Lab (FDITECH) and the Financial Crimes Enforcement Network (FinCEN) launched a digital identity Tech Sprint; FinCEN published a 60-day notice to...more
1/17/2022
/ (SEC) Rule 17a-4 ,
Bank Secrecy Act ,
Banking Sector ,
Broker-Dealer ,
Comment Period ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Financial Transactions ,
FinCEN ,
OMB ,
Proposed Amendments ,
Public Comment ,
Recordkeeping Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Security-Based Swaps
In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more
1/7/2022
/ Antitrust Division ,
Banking Sector ,
Banks ,
Beneficial Owner ,
Best Practices ,
Board of Governors ,
Broker-Dealer ,
Climate Change ,
Comment Period ,
Community Banks ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Depository Institutions ,
Disclosure Requirements ,
Division of Investment Management ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Foreign Corporations ,
Form CRS ,
Mergers ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Ownership Requirements ,
PCAOB ,
Proposed Rules ,
Public Comment ,
Publicly-Traded Companies ,
Registered Investment Advisors ,
Reporting Requirements ,
Repurchases ,
Retail Investors ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more
12/17/2021
/ 10b5-1 Plans ,
AML/CFT ,
Bank Secrecy Act ,
Banking Sector ,
Chief Compliance Officers ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Electronic Fund Transfer Act ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Insider Trading ,
Investment Company Act of 1940 ,
Investment Funds ,
Money Market Funds ,
OCC ,
Policies and Procedures ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Regulation E ,
Regulatory Agenda ,
Reporting Requirements ,
Request For Information ,
Risk Management ,
Rule 2a-7 ,
Rulemaking Process ,
SBS Entities ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Security-Based Swaps ,
Stock Repurchases ,
Swap Dealers ,
Trading Plans
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
12/10/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Amended Rules ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
CFTC ,
Comment Period ,
Continuing Education ,
Coronavirus/COVID-19 ,
Corporate Transparency Act ,
FDIC ,
FFIEC ,
Final Rules ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
FinCEN ,
Foreign Corporations ,
Libor ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Proposed Rules ,
Public Comment ,
Real Estate Transactions ,
Recordkeeping Requirements ,
Registration Requirement ,
Regulation Z ,
Reporting Requirements ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC)
In This Issue. The Consumer Financial Protection Bureau (CFPB) reminded institutions of a new threshold for reporting Home Mortgage Disclosure Act data about open-end lines of credit; the Financial Crimes Enforcement Network...more
11/22/2021
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
HMDA ,
Investment Adviser ,
Mortgage Lenders ,
Mortgages ,
Open-Ended Lines of Credit ,
Ransomware ,
Reporting Requirements ,
Risk Alert ,
Robo-Advisors ,
Securities and Exchange Commission (SEC) ,
Threshold Requirements
In This Issue. Federal agencies issued a joint statement regarding an orderly transition away from the London Interbank Offered Rate (LIBOR); the Office of the Comptroller of the Currency (OCC) issued an updated...more
10/22/2021
/ Bank Secrecy Act ,
Banking Sector ,
CFTC ,
Comment Period ,
Cyber Attacks ,
Cyber Crimes ,
Cyber Threats ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Environmental Social & Governance (ESG) ,
Financial Services Industry ,
FinCEN ,
Investors ,
Joint Statements ,
Libor ,
OCC ,
Proposed Rules ,
Public Comment ,
Ransomware ,
Secured Overnight Funding Rate (SOFR) ,
Suspicious Activity Reports (SARs)
In This Issue. The U.S. Securities and Exchange Commission (SEC) adopted amendments to modernize filing fee disclosure and payment methods; the Financial Industry Regulatory Authority (FINRA) announced an examination of...more
10/15/2021
/ Anti-Money Laundering ,
Automated Clearing House (ACH) ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Disclosure Requirements ,
Filing Fees ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Companies ,
Investors ,
Payment Methods ,
Securities and Exchange Commission (SEC) ,
Special Purpose Acquisition Companies (SPACs) ,
Terrorism Funding
In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more
7/28/2021
/ AML/CFT ,
Annual Reports ,
Anti-Money Laundering ,
Arkansas Teacher Retirement System v Goldman Sachs Group ,
Bank Secrecy Act ,
Banking Sector ,
Basic v Levinson ,
Borrowers ,
BSA/AML ,
Burden of Persuasion ,
Burden of Proof ,
Certiorari ,
Class Action ,
Class Certification ,
Community Development ,
Community Reinvestment Act ,
Conflicts of Interest ,
Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Distressed Properties ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Agencies ,
Financial Services Industry ,
FinCEN ,
Forbearance Agreements ,
Foreclosure ,
Goldman Sachs ,
Investors ,
Lenders ,
Loss Mitigation ,
Mortgage Lenders ,
Mortgage Servicers ,
Mortgages ,
No-Action Letters ,
OCC ,
Presumption of Reliance ,
Regulation X ,
Repeal ,
Rulemaking Process ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Litigation ,
Shareholders ,
True Lender ,
Underserved Locations
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve), in response to an increased number of inquiries and access requests from companies with fintech and other narrow purpose charters, invited...more
5/7/2021
/ Acquisitions ,
AMG Capital Management LLC v FTC ,
Anti-Money Laundering ,
Arbitration Agreements ,
Banking Sector ,
Broker-Dealer ,
Cash Transactions ,
Community Development Financial Institution (CDFI) ,
Consumer Financial Products ,
Depository Institutions ,
Enforcement Actions ,
Enforcement Authority ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
FinCEN ,
FinTech ,
FTC Act ,
FTCA Section 13(b) ,
Geographic Targeting Order ,
Injunctive Relief ,
Lenders ,
Loan Applications ,
Mergers ,
Paycheck Protection Program (PPP) ,
Payment Services Directive ,
Permanent Injunctions ,
Pre-Dispute Arbitration ,
Private Placements ,
Public Comment ,
Real Estate Transactions ,
Residential Real Estate Market ,
SBA ,
SCOTUS ,
Title Insurance ,
Unregistered Securities
In This Issue. The Consumer Financial Protection Bureau (CFPB) continued to be active under its new leadership this week, warning mortgage servicers to prepare now for an anticipated surge of homeowners needing assistance...more
4/8/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
ATDS ,
Auto-Dialed Calls ,
Beneficial Owner ,
Borrowers ,
Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Corporate Transparency Act ,
Debt Collection ,
Facebook ,
Facebook Inc v Duguid ,
FDIC ,
FinCEN ,
Foreclosure ,
Homeowners ,
Loss Mitigation ,
Mortgage Servicers ,
Mortgage Servicing Rules ,
Mortgages ,
Proposed Rules ,
Public Comment ,
Random or Sequential Number Generator ,
Regulation X ,
Robocalling ,
SCOTUS ,
TCPA
In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more
11/12/2020
/ Banking Sector ,
Banks ,
Blockchain ,
Board of Directors ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Cryptocurrency ,
Debt Settlement Services ,
Disclosure ,
Diversity ,
Enforcement Actions ,
FDCPA ,
FDIC ,
Federal Bank Regulatory Agencies ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Agencies ,
Financial Services Industry ,
FinCEN ,
Geographic Targeting Order ,
Interest Rates ,
Joint Statements ,
Libor ,
Loans ,
New Guidance ,
New Rules ,
No-Action Letters ,
OCC ,
Payday Loans ,
PayPal ,
Publicly-Traded Companies ,
Real Estate Transactions ,
Shareholders ,
Small Dollar Lenders ,
Student Loans ,
Telemarketing Sales Rule ,
Title Insurance
In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more
10/29/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Amended Rules ,
Bank Secrecy Act ,
Banking Sector ,
CFTC ,
Community Development Financial Institution (CDFI) ,
Comptroller ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Depository Institutions ,
Derivatives ,
FDCPA ,
FDIC ,
Federal Reserve ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Records ,
Financial Services Industry ,
FinCEN ,
FinTech ,
Forbearance Agreements ,
Insured Depository Institutions ,
Inter-Bank Offered Rates (IBORs) ,
Investors ,
ISDA ,
Military Service Members ,
Mortgages ,
OCC ,
Private Investment Funds ,
Proposed Rules ,
Proxy Statements ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Shareholder Proposals ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Travel Rule ,
True Lender ,
Truth in Lending Act (TILA)
In This Issue. The U.S. Supreme Court struck down the single director leadership structure of the Consumer Financial Protection Bureau (CFPB) in a ruling that could have far-reaching implications for the CFPB and other...more
7/6/2020
/ Banking Sector ,
Broker-Dealer ,
CFTC ,
Conflicts of Interest ,
Constitutional Challenges ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Dodd-Frank ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Eviction ,
FDIC ,
Federal Reserve ,
Fees ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Flood Insurance ,
Forbearance Agreements ,
Hemp Related Businesses ,
Investment Adviser ,
Investment Management ,
MNPI ,
OCC ,
OCIE ,
Paycheck Protection Program (PPP) ,
Popular ,
Private Equity Funds ,
Proposed Regulation ,
Removal For-Cause ,
Reversal ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Seila Law LLC v Consumer Financial Protection Bureau ,
Separation of Powers ,
Severability Doctrine ,
Single Director ,
Tenants
In This Issue. The ongoing global outbreak of the coronavirus (COVID-19) continues to grow in scale and scope. In response, federal financial regulators are continuing efforts to bring regulatory relief to promote stability...more
3/19/2020
/ Annual Meeting ,
Banking Sector ,
Comment Period ,
Coronavirus/COVID-19 ,
Enforcement ,
FDIC ,
Financial Institutions ,
Financial Markets ,
Financial Regulatory Agencies ,
Financial Services Industry ,
FinCEN ,
Infectious Diseases ,
Interim Final Rules (IFR) ,
Investment Adviser ,
Investment Funds ,
New Amendments ,
New Guidance ,
New Rules ,
OCC ,
Public Comment ,
Public Health ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
Shareholder Meetings ,
Virtual Meetings
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) have extended for an additional...more
7/25/2019
/ BSA/AML ,
FASB ,
Federal Trade Commission (FTC) ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
FinCEN ,
Mutual Funds ,
NYSE ,
Safe Harbors ,
Securities and Exchange Commission (SEC) ,
Volcker Rule
In This Issue. The Office of the Comptroller of the Currency (OCC) released its annual supervision operating plan outlining its bank supervision priorities, issued an updated Truth in Lending Act booklet, and provided...more
10/4/2018
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Corrective Actions ,
Cybersecurity ,
Financial Services Industry ,
FinCEN ,
Form 10-Q ,
Loans ,
OCC ,
Payday Loans ,
Securities and Exchange Commission (SEC) ,
Truth in Lending Act (TILA)