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Policies and Procedures Banks

A&O Shearman

FCA findings on multi-firm review of customers in vulnerable circumstances

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The UK Financial Conduct Authority (FCA) has published a webpage summarising the findings of its multi-firm review on retail banks' treatment of customers in vulnerable circumstances involving bereavement and power of...more

Orrick, Herrington & Sutcliffe LLP

FDIC updates electronic communication procedures for supervisory correspondence

On April 15, the FDIC announced updated guidance on sending official correspondence related to supervisory matters. The FDIC’s guidance made permanent those temporary, previous measures for electronically sending and...more

Hogan Lovells

Consumer Duty: UK FCA finds no room for complacency in firms’ treatment of customers in vulnerable circumstances involving...

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Outcomes testing and monitoring under the Consumer Duty, and senior management engagement with these areas, remain key focus areas for the FCA. Whilst the review in question focuses specifically on the treatment of customers...more

Troutman Pepper Locke

New York Federal Court Grants Bank’s Motion to Dismiss in Wire Fraud Case Involving Elderly Customer

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On December 18, the U.S. District Court for the Southern District of New York granted a bank’s motion to dismiss the complaint in a case involving wire transfers of an elderly customer who was the victim of an internet scam....more

Rumberger | Kirk

FINRA Reminds Financial Firms How AI Use Poses Significant Risks

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These days, artificial intelligence is everywhere we look, and the financial services industry is no different. As AI use increases, regulatory bodies are updating their rules and guidelines detailing how companies should and...more

ArentFox Schiff

DFS Issues Circular Letter Addressing Cybersecurity Risks Related to AI

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On October 16, the New York Department of Financial Services (DFS) issued a circular letter addressing cybersecurity risks related to the increasing use of artificial intelligence (AI) in relation to insurers, insurance...more

Hudson Cook, LLP

CFPB Issues Consent Order Related to Bank's Duplicative Force-Placed Insurance Policies

Hudson Cook, LLP on

On July 9, 2024, the Consumer Financial Protection Bureau issued a consent order against a nationally chartered bank that, among other things, includes a number of allegations related to the bank's policies regarding...more

Husch Blackwell LLP

FDIC Publishes FAQs on the New FDIC Signage, Advertisement, and Deposit Insurance Misrepresentations Rule

Husch Blackwell LLP on

Last week, the Federal Deposit Insurance Corporation (FDIC) published Frequently Asked Questions on the final rule governing FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured...more

Venable LLP

New Year, New Signs - FDIC Amends Deposit Insurance Sign and Advertising Regulations

Venable LLP on

After an intense 2023 rulemaking, supervisory, and enforcement cycle for the federal banking agencies, the FDIC issued a final rule on FDIC official signs and advertising requirements right before the new year. The rule comes...more

Husch Blackwell LLP

FDIC Amends Signage, Advertising, and FDIC Insurance Misrepresentation Rules to Address Digital Banking Services and Bank-Fintech...

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In December 2023, the Federal Deposit Insurance Corporation (FDIC) finalized amendments to its rules on official FDIC signage, bank advertisements, deposit insurance misrepresentations, and the misuse of the FDIC’s name or...more

Jenner & Block

Client Alert: The CFPB’s New “Open Banking” Rule: Consumers and Competition Expected to Win Once Policies and Procedures Ironed...

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Last week, the Consumer Financial Protection Bureau issued its long-awaited proposed rule to implement Section 1033 of the 2010 Consumer Financial Protection Act, which has come to be known as the “open banking” provision...more

Guidepost Solutions LLC

Compliance Experts Discuss Off-Channel Communications and Mobile Surveillance Policies

Roundtable Discussion: Off-Channel Communications and Mobile Surveillance Policies - Surveillance, monitoring, escalation, and reporting are critical components to regulatory compliance and risk management. So is...more

Sheppard Mullin Richter & Hampton LLP

OCC Revises Policies and Procedures for Civil Money Penalties

On November 29, the OCC released a revised Policies and Procedures Manual relating to the assessment of civil money penalties (“CMP Matrix”), which will be effective as of January 1, 2023. The CMP Matrix is a reference guide...more

White & Case LLP

Court of Appeal: Banks’ Quincecare duty may apply to instructions from defrauded customers

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In Philipp v Barclays Bank UK PLC, the Court of Appeal held that the Quincecare duty may apply to direct customer instructions (not just those through an agent), such that banks may be liable for failing to protect against...more

Woods Rogers

Banks Will Have 36 Hours to Report Cyberattacks Under New Rule

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The federal banking agencies recently issued a final regulation that will require a bank to notify its primary federal regulator of a cyberattack, or computer-security incident, no later than 36 hours after the bank...more

Moore & Van Allen PLLC

Advisory: Canada Designates Proud Boys a Terrorist Entity

Canada has designated the Proud Boys as a terrorist entity, meaning that banks and other financial services providers will no longer be allowed to deal with or facilitate transactions concerning property controlled by the...more

Society of Corporate Compliance and Ethics...

Compliance Perspectives: Due Diligence and Ultimate Beneficial Ownership (UBO)

For financial services firms understanding who the Ultimate Beneficial Owner (UBO) of a corporation is has become a central compliance task. As Ellen Lafferty explains in this podcast and in the new edition of The Complete...more

Orrick - Finance 20/20

OCC Extends Dodd-Frank Act Stress Test Requirements Through November 25

Orrick - Finance 20/20 on

The Office of the Comptroller of the Currency (OCC) announced that the deadline to comply with Dodd-Frank Act Stress Test (DFAST) requirements will be extended to November 25, and thereafter will be discontinued. ...more

BCLP

77 Percent of Bank Boards Commit this Mistake

BCLP on

Last week, Bank Director published a piece titled “77 Percent of Bank Boards Approve Loans. Is That a Mistake?” In case you didn’t get it from the title of this blog post, I think the answer is absolutely, 100 percent,...more

Ruder Ware

OCC Updates Guidance on Business Combinations

Ruder Ware on

The Office of the Comptroller of the Currency (“OCC”) has recently updated its “Business Combinations” booklet, which is part of the Comptroller’s Licensing Manual. The revised booklet replaces the prior version, which was...more

Ballard Spahr LLP

OCC establishes framework for evaluating applications from banks with less than satisfactory CRA rating

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In a new Policies and Procedures Manual (PPM) issuance (PPM 6300-2), the OCC establishes its framework for evaluating certain types of licensing applications when the applicant bank has an overall Community Reinvestment Act...more

Troutman Pepper Locke

OCC's High-LTV Bulletin Is a Win for Banks and Consumers

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Since the financial crisis, it has been difficult for consumers and developers to obtain mortgages to buy and build in the areas most hurt by the recession. The Office of the Comptroller of the Currency (OCC) has...more

Stinson - Corporate & Securities Law Blog

The New York State Department of Financial Services Proposes Robust Cybersecurity Rules

On September 13, 2016, the New York State Department of Financial Services (DFS) proposed new rules that would require certain “Covered Entities” to establish and implement cybersecurity programs designed to protect nonpublic...more

Ballard Spahr LLP

CFPB issues guidance on deposit reconciliation practices

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The CFPB and four other agencies have issued “Interagency Guidance Regarding Deposit Reconciliation Practices.”  The other agencies are the OCC, Fed, FDIC, and NCUA.  The guidance is intended to set forth the agencies’...more

Stinson - Corporate & Securities Law Blog

New Proposed Rules on Banker Incentive Compensation Released

The National Credit Union Administration, or NCUA, became the first of six Agencies to unveil a revised rule proposal under Section 956 of the Dodd-Frank Act: prohibiting incentive-based payment arrangements that the...more

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