A Look at Recent Federal Trade Commission and Consumer Financial Protection Bureau Initiatives Concerning Privacy and Data Security
2BInformed: Engaging with EPA, OSHA’s New Regulation, and Asbestos
In the March edition of our Public Company Watch, we cover key issues impacting public companies, including the new climate disclosure rules, SEC scrutiny on beneficial ownership filings, West Palm Beach Firefighters’ Pension...more
In a post-FTX environment, several financial regulators are taking action to emphasize a policy of sound custody and disclosure practices and to better understand certain risks to protect customers in the event of an...more
SEC Division of Examinations Issues Risk Alert on Regulation S-ID and Identity Theft Prevention Programs - On December 5, 2022, the Securities and Exchange Commission (“SEC”) Division of Examinations (“EXAMS”) issued a...more
SEC Chair Gensler Indicates Commission is Looking to Update SEC’s Regulation S-P - On September 28, 2022, Securities and Exchange Commission (“SEC” or the “Commission”) Chairman Gary Gensler appeared via video at the...more
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
Democrats Begin Process of Enacting Administration’s Domestic Goals. It took some good old-fashioned politicking, but earlier this week the U.S. House of Representatives approved a $3.5 trillion budget resolution that...more
On April 1, 2021, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comments on the implementation of the Corporate...more
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
In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more
In This Issue. The Securities and Exchange Commission (SEC) finalized amendments to its proxy solicitation rules that will modify the practices of proxy advisory firms, providing them with greater transparency and...more
In This Issue. The Office of the Comptroller of the Currency (OCC) released an advanced notice of proposed rulemaking seeking comments on several issues related to digital technology and innovation, as well as proposed...more
EDITOR'S NOTE - Working Weekends and Holidays. While most Americans were enjoying the Independence Day holiday weekend, the Board of Governors of the Federal Reserve System (Federal Reserve), the Office of the Comptroller of...more
The National Credit Union Administration (“NCUA”) has issued an Advanced Notice of Proposed Rulemaking (the “Rulemaking”) addressing the use of alternative capital for federally insured credit unions (“FICUs”)....more
Financial Industry Developments - Federal Reserve Board Announces Finalized Rule Adjusting the Board's Maximum Civil Money Penalties - On January 18, 2017, the Federal Reserve Board announced that it was adjusting...more
Editor's Note - In This Issue.The SEC and FINRA released their examination priorities for 2017; the SEC’s Division of Investment Management issued an interpretative letter that would permit brokers to charge their own...more
On November 14, 2016, the Securities and Exchange Commission (SEC) held its first public forum to discuss financial technology (“Fintech”) innovation in the financial services industry. The Fintech Forum was divided into four...more
At the NCUA’s October board meeting, senior staff of the NCUA submitted a briefing report (the “Report”) to the NCUA Board (the “Board”) on the issues concerning the use of supplemental capital by federally insured credit...more
Financial Industry Developments - Agencies Issue Advanced Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards - On October 19, 2016, the Federal Reserve Board, the Federal Deposit Insurance...more
Editor's Note - Another Cybersecurity Proposal. On the heels of the New York State Department of Financial Services (NYDFS) issuing its proposed regulation that would require banks and insurance companies to institute...more
The SEC’s December advance notice of proposed rulemaking, concept release and request for comment (ANPR) concerning its transfer agent rules, may foreshadow significant changes for mutual fund transfer agents. Even though...more
SEC proposal would modernize the regulation of the transfer agency industry, particularly with respect to mutual funds. Last month, the US Securities and Exchange Commission (SEC) issued an Advance Notice of Proposed...more
On December 22nd, 2015, the Commission issued an advanced notice of proposed rulemaking (ANPR) for new requirements for transfer agents, together with a concept release requesting public comment on the Commission’s broader...more
The SEC has issued a release soliciting comment on the regulation of transfer agents. After some initial background, it’s divided into two parts. The first is an advance notice of proposed rulemaking, seeking comment on...more