Discrimination and Bias in Residential Lending
The Importance of Assessment Areas
On April 30, 2010, the Federal Financial Institutions Council (FFIEC) issued Guidance on the use of cloud computing services and security risk management principles in the financial services sector. The Guidance reminds...more
In December 2016, Thomas Curry, the Comptroller of the Currency, stated that cybersecurity was the single greatest systemic threat to our financial system. He was not being hyperbolic. Cybersecurity should be on...more
Last week, FinCEN (Financial Crimes Enforcement Network) issued a formal Advisory to Financial Institutions and published FAQs outlining specific cybersecurity events that should be reported through Suspicious Activity...more
The Federal Financial Institutions Examination Council (FFIEC)—the interagency body tasked with setting uniform principals and standards for the examination of financial institutions by federal prudential regulators,...more
The Consumer Financial Protection Bureau (CFPB) announced its intention to act as a data security regulator by releasing its first unfair, deceptive or abusive acts or practices (UDAAP) enforcement action for allegedly...more
BELTWAY - Every Last Penny Counts - Five federal banking agencies issued a Supervisory Bulletin titled “Interagency Guidance Regarding Deposit Reconciliation Practices” (the “Guidance”). The Guidance outlines...more
Examiners will be paying more attention to mobile financial services (MFS) using new guidance recently issued by the Federal Financial Institutions Examination Council (FFIEC)....more
The Federal Financial Institutions Examination Council recently issued a new appendix on “Mobile Financial Services” to the Retail Payment Systems booklet of the FFIEC Information Technology Handbook. The appendix...more
Competition and technology are demanding that banks provide more convenient payment choices for consumers. Consequently, banks are offering mobile financial services (MFS) that can be accessed through mobile devices such as...more
On February 1, 2016, the Federal Deposit Insurance Corporation (“FDIC”) published the Winter 2015 issue of Supervisory Insights. Not surprisingly, the first article dealt with the most important issue facing the financial...more
All organizations, including financial institutions, continue to face significant security threats across their wide ranging IT systems. Such organizations are particularly vulnerable if they cannot track networked devices...more
Banks are tasked by the Uniform Commercial Code (the UCC) with using “commercially reasonable” security procedures when processing funds transfers. This responsibility is constantly evolving as bank fraud becomes more...more
In This Issue: IN THE SPOTLIGHT - - Your Data Breach Collided With My Personal Injury Coverage LIFE INSURANCE - - Phantom Injury Dooms “Shadow Insurance” Case - Latest NAIC Cybersecurity News ...more
As financial institutions of all sizes continue to face unprecedented cybersecurity risk, the Federal Financial Institutions Examination Council (FFIEC) released its Cybersecurity Assessment Tool. The Assessment is...more
BELTWAY - Straight Out of the Seventh Circuit The Seventh Circuit recently affirmed a lower court’s ruling that the SEC cannot be sued in district court to stop it from bringing an administrative action. Bebo v. SEC, No....more
On September 15, the U.S. Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert regarding the SEC’s ongoing cybersecurity examinations of registered broker-dealers...more
Part of Bradley Arant’s Privacy and Information Security Team’s seven-part Data Breach Toolkit Webinar Series, the “Data Breach Response Planning: Laying the Right Foundation” webinar, led by Paige Boshell and Amy Leopard,...more
Could your institution be at risk of liability for unauthorized wire transfers and Automated Clearing House (“ACH”) credit transfers? Data security breaches continue to garner headlines, and criminals continue to engage in...more
Earlier this summer, the Federal Financial Institutions Examination Council (FFIEC) released its highly anticipated Cybersecurity Assessment Tool (Assessment), which is designed to assist financial institutions in identifying...more
The Federal Financial Institutions Examination Council (FFIEC) has recently developed a new tool to help U.S. financial institutions combat the increasing volume and sophistication of cyber attacks. To blunt threats to a...more
Seventh Circuit Decision May Make It Easier for Class Action Plaintiffs to Establish Standing in Data Breach Cases - The Seventh Circuit has issued a decision that could make it much easier for class action plaintiffs to...more