Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
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
Regulatory Developments - Overdraft Protection Programs: Risk Management Practices - On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more
To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week...more
Crypto Products Launch, Reports Detail CBDC Pilots and Bank Crypto Exposure - Last week, Circle Internet Financial, the issuer of USD Coin (USDC), announced plans “to make USDC available on five additional blockchain...more
On April 14, 2021, the U.S. Senate confirmed the nomination of Gary Gensler as the 33rd Chair of the U.S. Securities and Exchange Commission (“SEC” or “Commission”). This change will bring forth a Democratic majority at the...more
Appearing before the House Financial Services Committee Tuesday at a hearing entitled “The Annual Report of the Financial Stability Oversight Council” (FSOC), Treasury Secretary Mnuchin indicated that he intends to discuss...more
House Financial Services Committee Votes To Repeal And Replace Dodd-Frank - On September 13th, the House Financial Services Committee approved the Financial CHOICE Act of 2016 to repeal and replace key parts of the 2010...more
Editor's Note - MetLife Fights On. MetLife continued to fight its designation as a nonbank systemically important financial institution (SIFI) this week as the insurer filed its reply brief in the Financial Stability...more
Regulatory Developments - SEC Issues Order Approving Inflation Adjustments to “Qualified Client” Dollar Thresholds for Investment Adviser Performance Fee Rule - On June 14, the SEC issued an order approving...more
Regulatory Developments - Cordray Testifies before Senate Banking Committee - On April 7, Consumer Financial Protection Bureau (CFPB) Director Richard Cordray testified before the Senate Banking Committee during the...more
CFTC Again Extends Deadlines for New OCR Compliance; Puts Pressure on FCM Clients Who Will Not Provide Adequate Information Regarding Trading Control - Late last week, staff of the Division of Market Oversight of the...more
Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more
In State National Bank of Big Spring v. Lew, the United States Court of Appeals for the District of Columbia Circuit ruled that the plaintiff had standing to challenge the constitutionality of the CFPB. The Court made quick...more
Regulatory Developments - Agencies Post Public Sections of Resolution Plans: In a July 6 joint press release, the Federal Reserve Board and FDIC announced that they have posted the public portions of annual...more