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Hudson Cook, LLP

CFPB Bites of the Month - May 2024 - CFPB: Light My Way, Virginia May

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In this month's article, we share some of our top "bites" covered during the May 2024 webinar....more

Venable LLP

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

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It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more

Ballard Spahr LLP

Districts of Wyoming and Idaho Affirm Broad Fed Powers over Master Accounts

Ballard Spahr LLP on

Components of the U.S. Federal Reserve System recently prevailed in two lawsuits in which both plaintiffs – Custodia Bank and PayServices Bank – alleged the defendants were required to grant the plaintiffs’ master account...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - March 2024 - 2

Editor's Note - The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency,...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Ballard Spahr LLP

ICBC Agrees to Two Consent Orders for Alleged BSA/AML Deficiencies and Disclosure of Confidential Supervisory Information

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Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Ballard Spahr LLP

SDNY Court Finds Broad Fed Powers Over Master Accounts in Puerto Rican Bank Case Involving AML Concerns

Ballard Spahr LLP on

The United States District Court for the Southern District of New York (the “Court”) has issued a detailed and complicated Order in the case Banco San Juan Internacional, Inc. v. Fed. Reserve Bank of New York, denying a...more

Kilpatrick

A Regulatory Enforcement Roundup

Kilpatrick on

A periodic review of regulatory enforcement actions is a useful guide to what not to do in the financial services sector. This post focuses on several recent enforcement actions – one by the Federal Reserve Board (the...more

Ballard Spahr LLP

Minnesota Bankers Association and Lake Central Bank sue FDIC over NSF fee guidance

Ballard Spahr LLP on

A complaint filed on July 20, 2023 in Minnesota federal court seeks declaratory and injunctive relief under the Administrative Procedures Act (APA) against defendants Federal Deposit Insurance Corporation (FDIC) and Chairman...more

Cadwalader, Wickersham & Taft LLP

FRB Issues Policy Statement on Permissible Activities of State Member Banks While Denying Uninsured Crypto-focused Bank’s...

The Federal Reserve Board (“FRB” or “Board”) issued two seemingly related press releases late last week. The first announced the denial of the Federal Reserve membership application by Custodia Bank, a Wyoming special purpose...more

Goodwin

Federal Reserve Seeks Feedback on Proposed Updates to FMUs Risk Management Requirements

Goodwin on

Regulatory Developments - Federal Reserve Seeks Feedback on Proposed Updates to FMUs Risk Management Requirements - On September 23, the Federal Reserve invited comment on proposed updates to operational risk...more

Goodwin

Fed Proposes Guidelines for Access to Master Accounts and Payment Services

Goodwin on

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

Goodwin

SBA Implemented Changes to PPP as a Part of American Rescue Plan Act

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In this Issue. The federal bank regulatory agencies announced that the temporary change to the supplementary leverage ratio for depository institutions will expire as scheduled on March 31, 2021; the Small Business...more

Goodwin

SEC Issues No-Action Relief On Registered Funds’ Custody Of Loan Interests

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In this Issue. The U.S. Securities and Exchange Commission (SEC) was very active this week, having (i) issued no-action relief allowing registered funds to engage in self-custody of interests in loans that are originated,...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

Goodwin on

In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

Goodwin

Financial Services Weekly Roundup: The Supreme Court Strikes Back On Single Director Leadership Structures

Goodwin on

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

Goodwin

Financial Services Weekly Roundup: The OCC Proposes New Rulemaking And Changes To Address Innovation And Consumer Needs

Goodwin on

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

Goodwin

Financial Services Weekly Roundup: May Introduces Additions And Expansions To Covid-19-related Policies

Goodwin on

In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve) expanded access to its Paycheck Protection Program Liquidity Facility (PPPLF) to non-bank lenders and expanded the collateral eligible to...more

Goodwin

Financial Services Weekly Roundup: PPP Borrowers And Lenders Under The Microscope

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule that would establish a revised framework for the fair value determination for purposes of the Investment Company Act of 1940 and have...more

Goodwin

Financial Services Weekly Roundup: Priming The Pump – Additional Actions To Combat COVID-19

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Priming the Pump. As the COVID-19 outbreak continues, the Board of Governors of the Federal Reserve System (Federal Reserve), consistent with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), took additional...more

Sheppard Mullin Richter & Hampton LLP

Fed’s Vice Chair for Supervision Proposes a Deregulatory Approach to Limit the Scope of “Matters Requiring Attention” used in Bank...

A January proposal to give banks compliance slack floated by a high-ranking Federal Reserve Board (“FRB”) official has not yet gained the traction its supporters had hoped for. In remarks before the American Bar Association...more

Goodwin

Financial Services Weekly Roundup: Financial Regulators Ramp Up Measures To Address Covid-19

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In This Issue. In response to the ongoing global outbreak of the coronavirus (COVID-19), federal financial regulators continue to take aggressive actions to promote stability to the financial markets. The Board of Governors...more

Seyfarth Shaw LLP

The Week in Weed: December 2019

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Welcome back to The Week in Weed, your Friday look at what’s happening in the world of legalized marijuana. New Jersey is talking about decriminalizing marijuana. Regular readers will doubtless recall that legalization...more

Kramer Levin Naftalis & Frankel LLP

The Financial CHOICE Act Is Approved by US House Financial Services Committee

On May 4, the Financial CHOICE Act (the FCA) — which was introduced to the House of Representatives on April 26 by Rep. Jeb Hensarling (Texas-5), and co-sponsored by seven of his Republican colleagues and referred for...more

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