Nutter Bank Report, May 2018

by Nutter McClennen & Fish LLP
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Headlines

  1. Economic Growth, Regulatory Relief, and Consumer Protection Act Signed into Law
  2. FFIEC Publishes Guidance for New Customer Due Diligence Requirements
  3. New Electronic Check Warranties and Indemnities Become Effective on July 1
  4. SEC Proposes Broker-Dealer Best Interest Rule and Related Guidance
  5. Other Developments: CECL Implementation and Servicemember Lending

1. Economic Growth, Regulatory Relief, and Consumer Protection Act Signed into Law

President Trump signed into law the Economic Growth, Regulatory Relief, and Consumer Protection Act (the “EGRRCPA”) on May 24. The EGRRCPA provides targeted relief from several key components of the Dodd-Frank Act, primarily for community banks, and includes amendments to a variety of post-crisis legal and regulatory reforms across a wide range of financial services providers. Forms of regulatory relief for community banks include the creation of a new community bank leverage ratio (“CBLR”), extended examination cycles, expanded short-form Call Reports, and an increase in the Small Bank Holding Company and Savings and Loan Holding Company Policy Statement’s asset threshold. The EGRRCPA also expands the safe harbor for Qualified Mortgages to certain home mortgage loans held in portfolio by community banks and provides targeted relief from Home Mortgage Disclosure Act reporting requirements. In addition, the EGRRCPA creates a new option for federal savings associations to exercise the same powers as national banks and exempts certain banking entities from the prohibitions of the so-called “Volcker Rule.” For a copy of Nutter’s detailed Review and Analysis of the EGRRCPA, click here. Click here for a copy of the text of the legislation.

    Nutter Notes: Under the EGRRCPA, the federal banking agencies must develop rules establishing the CBLR—which is the ratio of an institution’s equity capital to its consolidated assets—between 8% and 10% for “qualifying community banks.” A qualifying community bank is an insured depository institution or depository institution holding company with total consolidated assets of less than $10 billion that is not determined ineligible by the appropriate federal banking agency due to its risk profile. If a qualifying community bank exceeds the CBLR, the EGRRCPA mandates that the qualifying community bank will be considered to have met the generally applicable leverage and risk-based capital requirements and any other capital including leverage requirements applicable to it, with certain exceptions. The EGRRCPA also directs the federal banking agencies to consult with the applicable state bank supervisor concerning the CBLR, and to notify the applicable state bank supervisor of any qualifying community bank that it supervises that no longer exceeds the CBLR.

2. FFIEC Publishes Guidance for New Customer Due Diligence Requirements

The FFIEC has issued examination procedures for the new rules on customer due diligence and beneficial ownership for legal entity customers, with which compliance became mandatory as of May 11, 2018. The FFIEC’s bank examination procedures published on May 11 replace the section in the 2014 FFIEC BSA/AML Manual entitled “Customer Due Diligence – Overview and Examination Procedures,” and add a new section entitled “Beneficial Ownership Requirements for Legal Entity Customers – Overview and Examination Procedures.” The new sections of the manual include the bank examination procedures that will be used by each banking agency’s examiners. As explained in more detail in the new sections of the manual, the rules include both minimum customer due diligence program requirements and a new requirement to identify and verify the identity of individuals who own or control legal entity customers (i.e., beneficial owners), subject to certain exclusions and exemptions. The new sections of the manual emphasize that examiners will expect each bank to demonstrate effective management of its BSA/AML risk by developing BSA/AML compliance programs tailored to the bank’s risk profiles. Click here for access to the new examination procedures.

    Nutter Notes: According to the new customer due diligence section of the manual, examiners will expect each bank to demonstrate an understanding of the money laundering and terrorist financing risks of its customers, referred to in the rules as the customer risk profile. The examination procedures explain that the bank’s program for determining customer risk profiles should be sufficiently detailed to distinguish between significant variations in the money laundering and terrorist financing risks of its customers. The new examination guidance warns that improper identification and assessment of a customer’s risk profile create deficiencies in multiple areas of internal controls and result in an overall weakened BSA compliance program. The new customer due diligence section of the manual explains that a bank may rely on information supplied by a legal entity customer regarding the identity of its beneficial owner or owners, as long as the bank has no knowledge of facts that would reasonably call into question the reliability of such information. If bank staff know, suspect, or have reason to suspect that a beneficial owner is attempting to avoid the reporting threshold, however, the bank may be required to file a SAR, according to the new examination guidance.

3. New Electronic Check Warranties and Indemnities Become Effective on July 1

The Federal Reserve’s amendments to its Regulation CC (Availability of Funds and Collection of Checks), which include modifications to check return requirements and a new indemnity for remote deposit capture, become effective on July 1, 2018. The amendments to Regulation CC approved last year create a new framework for electronic check collection. The amendments apply Regulation CC’s existing check warranties for paper checks to checks that are collected electronically, and apply new warranties and indemnities to checks collected and returned electronically and to electronically-created items. The amendments also add new indemnities for electronically-created items, which are check-like items created in electronic form that never existed in paper form. Click here for the text of the amendments to Regulation CC.

    Nutter Notes: The new indemnity for remote deposit capture under Regulation CC provides that a bank that accepts a remote deposit of an electronic check or substitute check must indemnify a bank that accepts the original paper check for deposit if the check is returned unpaid because the electronic or substitute check derived from it was previously paid by the drawee bank. There is an exception to the new indemnity, however, that will prevent an indemnified bank (the bank that accepts the original paper check) from making an indemnity claim if the original paper check has a restrictive indorsement that is inconsistent with the means of deposit, such as “for mobile deposit only.” Therefore, banks that accept checks through a remote deposit capture service should consider modifying their remote deposit capture service agreements with customers to include a requirement that the customer add a restrictive indorsement to each original paper check submitted for deposit electronically, such as “For Mobile Deposit Only,” along with appropriate remedies for the customer’s failure to do so that result in an indemnity claim made by another depository institution for the same check.

4. SEC Proposes Broker-Dealer Best Interest Rule and Related Guidance

The U.S. Securities and Exchange Commission (“SEC”) has issued a package of proposed rules and a regulatory interpretation to “enhance the quality and transparency of investors’ relationships with investment advisers and broker-dealers.” The proposed rules published last month include a so-called best interest requirement for broker-dealers, an interpretation of the fiduciary duty that investment advisers owe to their clients, and a new short-form disclosure document for investment advisers and broker-dealers. Under the proposed best interest rule, a broker-dealer would be required to act in the best interest of a retail customer when making a recommendation of any securities transaction or investment strategy involving securities to a retail customer. Under the proposed rule, a retail customer is a person (or his or her legal representative) who uses the recommendation primarily for personal, family, or household purposes. The coinciding proposed regulatory interpretation of the standard of conduct for investment advisers under the Investment Advisers Act of 1940 would reaffirm and clarify the fiduciary duty that an investment adviser owes to its customers, including the duty to provide advice that is in each customer’s best interest. Click here for the proposed best interest rule, here for the proposed regulatory interpretation, and here for the corresponding proposed short-form disclosure document for investment advisers and broker-dealers. Public comments on the proposals are due by August 7.

    Nutter Notes: According to the SEC, the proposed best interest rule and investment adviser interpretation are intended to make clear that broker-dealers and investment advisers may not put their financial interests ahead of the interests of their customers in making investment recommendations. The proposed interpretation also clarifies the duty of an investment adviser to seek best execution and to provide advice and monitoring over the course of the customer relationship, and the duty not to favor one customer over another, to make full and fair disclosure, and to avoid conflicts of interest. The SEC proposed a new short-form disclosure document—a customer or client relationship summary—to help address investor confusion about the nature of their relationships with broker-dealers and investment advisers. The new disclosure form would provide retail investors with summary information about the nature of their relationship with their investment professional and would supplement other more detailed disclosures. For broker-dealers, disclosures of the material facts relating to the scope and terms of the relationship would be required under the new best interest rule. For investment advisers, more detailed information would be found in Form ADV.

5. Other Developments: CECL Implementation and Servicemember Lending

  • Federal Bank Agencies Propose Capital Rule Amendments to Implement CECL Standard

The federal banking agencies have jointly issued proposed amendments to their regulatory capital rules that would implement the Financial Accounting Standards Board’s current expected credit losses (“CECL”) standard. The proposed revisions published on May 16 would conform definitions in the agencies’ rules to the CECL standard and provide an optional transition framework for banks that experience a decrease in capital as a result of adopting the CECL standard. Public comments on the proposed amendments are due by July 13.

    Nutter Notes: According to the agencies, upon adopting CECL, a banking organization will be required to record an adjustment to its credit loss allowances equal to the difference between the amount of credit loss allowances required under the incurred loss methodology and the amount of credit loss allowances required under the CECL standard. The agencies have allowed that it is possible that, despite adequate planning to prepare for the implementation of the CECL standard, unexpected economic conditions at the time of CECL adoption could result in higher-than-anticipated increases in allowances, because CECL requires banking organizations to consider current and future expected economic conditions to estimate allowances and these conditions will not be known until closer to a banking organization’s CECL adoption date. To relieve such a negative impact, the proposed amendments would provide a banking organization with the option to phase in over a three-year period the day-one adverse effects of CECL on the banking organization’s regulatory capital ratios. Click here for a copy of the proposed amendments.

  • OCC Publishes Revised Guidance on Consumer Credit Extended to Servicemembers

The OCC has issued a new Military Lending Act (“MLA”) booklet of the Comptroller’s Handbook. The new booklet published on May 11 provides examination guidance on compliance with the MLA and its implementing rules that address limitations on consumer credit extended to servicemembers and their dependents. The MLA applies to closed-end and most open-end consumer credit extended on or after October 3, 2016, and to credit card accounts established on or after October 3, 2017, that are covered by the MLA and its implementing rules.

    Nutter Notes: The new MLA booklet replaces and rescinds the “Limitations on Terms of Consumer Credit Extended to Servicemembers and Dependents” procedures in the “Other Consumer Protection Laws and Regulations” booklet of the Comptroller’s Handbook. The new MLA booklet reflects U.S. Department of Defense amendments to the MLA implementing rules that were first published in the Federal Register on July 22, 2015, and related official Defense Department interpretations. Click here for a copy of the revised MLA booklet.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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