News & Analysis as of

Branch Offices

Ogletree, Deakins, Nash, Smoak & Stewart,...

Where Digital Nomad Visas Miss the Mark

Countries around the globe are establishing digital nomad visa regulations to allow foreign employees to enter the countries and work exclusively for foreign employers for short periods of time—generally, between six and...more

Amundsen Davis LLC

3 Real Estate Issues Facing All Bank Branches

Amundsen Davis LLC on

Banks own and operate a Real estate contractsurprising amount of real estate for their branches and offices. There were over 77,500 bank branches in America as of the end of 2023. By comparison, McDonalds has about 13,000...more

Mayer Brown

FHA Branch Offices Could Become a Thing of the Past: HUD Finalizes Rule Eliminating Mandatory Branch Office Registration

Mayer Brown on

Federal Housing Administration (“FHA”) approved lenders and mortgagees will no longer be required to register their branch offices. The US Department of Housing and Urban Development (“HUD”) published a final rule (the “Final...more

Goodwin

FINRA Approves Remote Branch Inspection Pilot Program

Goodwin on

On January 23, 2024, FINRA announced the addition of new Supplementary Material .18 to FINRA Rule 3110 (Supervision) to adopt a voluntary, three-year remote inspections pilot program (Pilot Program) to allow eligible members...more

Goodwin

FINRA (Finally) Adopts Work-From-Home Supervisory Location Category and Requirements

Goodwin on

Firms will be able to treat private residences from which certain supervisory activity is conducted as non-branch offices instead of OSJs. The adoption comes after nearly two years of FINRA efforts to align its supervisory...more

Latham & Watkins LLP

FINRA Adopts New Residential Supervisory Location Rule on Remote Work for Associated Persons

Latham & Watkins LLP on

The new rule establishes criteria for firms to elect “non-branch” designation for a private residence where an associated person engages in specified supervisory activities....more

Goodwin

FINRA Re-Proposes Work-From-Home Supervisory Locations

Goodwin on

Firms would be able to treat private residences as non-branch offices instead of OSJs under certain circumstances. FINRA hopes to align its supervisory rules with current work-from-home practices....more

Akin Gump Strauss Hauer & Feld LLP

NFA Proposes to Amend the Branch Office Definition, Embraces the ‘New Normal’ of Remote Working for CPOs and CTAs

Key Points - Beginning as early as September 2, 2021, a “branch office” for NFA purposes will exclude any remote working location not held out to the public as a CPO or CTA office where one or more APs from the same...more

Miles & Stockbridge P.C.

It's Time to Dispense with Branch Office Licensing

Well, summer is more than half over, and although the initial pandemic has nearly run its course, a new COVID variant appears to be on the rise. Before we hunker down and mask up to fight off this stronger DELTA version of...more

Miles & Stockbridge P.C.

Further Guidance Regarding Relief from Branch Office Licensing

In response to the many disruptions caused by the COVID-19 pandemic many states have made accommodations for certain licensing requirements across various industries. Last month, in our blog post “Relief from Branch Office...more

Miles & Stockbridge P.C.

Relief from Branch Office Licensing

Last year, when COVID-19 first hit the country nationwide, many state regulators were quick to act, and temporarily allowed licensed companies and their licensed mortgage loan originators (“MLOs”) to originate residential...more

Goodwin

FDIC Finalizes Brokered Deposits and ILC Rules Ahead of the Holidays

Goodwin on

In this Issue. The Federal Deposit Insurance Corporation (FDIC) was busy this week, finalizing rules that modernize brokered deposits regulations, establish new standards for parent companies of industrial loan companies and...more

McGlinchey Stafford

FDIC Issues Final Rule Codifying Valid When Made Doctrine

McGlinchey Stafford on

At long last, the FDIC has issued its final rule codifying the “valid when made” doctrine. The rule was finalized on June 25, 2020, and clarifies that the interest rate lawfully assessed by an originating depository...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

USCIS to Resume Public Services for Domestic Offices on June 4, 2020

U.S. Citizenship and Immigration Services (USCIS) will reopen some domestic offices to resume non-emergency services on June 4, 2020. USCIS suspended routine in-person services on March 18, 2020, in response to the COVID-19...more

Dechert LLP

CFTC and NFA Issue Relief for Registered CPOs and CTAs in Response to Disruptions Caused by COVID-19 Coronavirus Pandemic

Dechert LLP on

The Commodity Futures Trading Commission issued industry-wide no-action relief for registered commodity pool operators on March 20, 2020, to permit those CPOs additional time to make certain regulatory filings and issue...more

Vedder Price

NFA Issues COVID-19 Alert on Business Continuity Plans, Relief for Branch Office Requirements and Reminder on Upcoming Deadline...

Vedder Price on

On March 4, 2020, the National Futures Association (the “NFA”) issued a notice to its members addressing concerns surrounding the coronavirus (COVID-19). With the coronavirus’s potential to interfere with members’ regulatory...more

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