In this update, we focus on the potential changes in the executive branch and on the congressional committees that have jurisdiction over cryptocurrency. As the transition unfolds, much attention is on who will stay from the...more
But upon closer consideration, there is an interplay between a bank partner program and the Electronic Fund Transfer Act (EFTA) as implemented by Regulation E, particularly when it comes to timeframes for disputes, liable...more
Federal Reserve Issues Guidance on Stablecoin Issuances by State-chartered Member Banks- The Board of Governors of the Federal Reserve System announced the creation of a new supervision program addressing novel activities...more
July 14, 2023- The Chairman of the House Financial Services Committee, Patrick McHenry (NC-10), and the Chairman of the House Agriculture Committee, Glenn "GT" Thompson (PA-15), issued the following statement regarding the...more
On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more
On June 6, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency jointly released final guidance on managing risks associated...more
En enero del 2023, Agencias Reguladoras; incluyendo la Junta de Gobernadores del Sistema de la Reserva Federal, la Corporación Federal de Seguros de Depósitos y la Oficina del Contralor emitieron una Declaración Conjunta...more
March 14, 2023- The Federal Deposit Insurance Corporation issued Financial Institution Letter 10-2023 indicating that financial institutions are required to meet contractual obligations with bridge banks established to...more
UPDATE (3/12 PM): U.S. Treasury Uses Systemic Risk Exception to Protect Depositors of Failed Banks and the Federal Reserve Board Establishes New Emergency Facility. Following the failure of Silicon Valley Bank (SVB) on...more
On January 3, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) issued a joint...more
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
In This Issue. The Federal Housing Finance Agency (FHFA) announced that Fannie Mae and Freddie Mac will no longer charge lenders the Adverse Market Refinance Fee; the Federal Deposit Insurance Corporation (FDIC) is seeking...more
On July 26, 2021, Neal R. Pandozzi participated as a presenter in the Strafford CLE webinar "The Phase-out of LIBOR: Navigating the Final Stages, Implementing Alternative Reference Rates and Fallback Language." The webinar...more
In this Issue. The Consumer Financial Protection Bureau (CFPB) issued a statement announcing its intention to revisit Trump-era qualified mortgage (QM) final rules; the Biden Administration announced changes to the Small...more
The Intercontinental Exchange (ICE) Benchmark Administration (IBA), which is the administrator of the London Interbank Offered Rate (Libor), announced on Nov. 30, 2020, that it will consult in early December on its intention...more
In This Issue. The Office of the Comptroller of the Currency (OCC) proposed a rule that would establish that a national bank or federal savings association is the “true lender” of a loan if, as of the date of origination, the...more