Navigating Consumer Protection: The CFPB's Expanding Reach — Payments Pros – The Payments Law Podcast
Understanding Scope of Practice
Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
On April 17, 2025, the Commodity Futures Trading Commission’s (CFTC) Market Participants Division (MPD), the Division of Clearing and Risk (DCR), and the Division of Market Oversight (DMO)—collectively the Operating...more
The three operating divisions of the CFTC (Division of Market Oversight, Market Participants Division, and the Division of Clearing and Risk, together the Operating Divisions) issued an advisory on April 17, explaining the...more
The Basel Committee on Banking Supervision (BCBS) has published a press release providing an update on its workstreams. The BCBS states that it will publish by mid-2025 an update on the outcome of its work to prepare a suite...more
On 26 February 2025, the Financial Conduct Authority (FCA) published a portfolio letter (Letter) explaining its supervision priorities for the asset management and alternatives portfolios....more
The Financial Markets Standards Board has published its updated final statement of good practice for front office supervision of wholesale traded markets. The statement of good practice sets out 15 good practice statements,...more
This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more
The recent bank regulatory Joint Statement and request for information (RFI) on third-party deposit relationships and bank-fintech partnerships emphasize afresh regulators’ long-standing concern with financial institutions’...more
Since the 2023 spring bank failures, the federal banking agencies have tinkered with significant bank regulations and guidance—ranging from capital, bail-in measures, and resolution planning to climate-risk stress testing,...more
On January 17, acting Comptroller of the Currency Michael J. Hsu delivered remarks at the Brookings Institute regarding large bank manageability. Hsu started by expressing his belief that developing a robust approach to...more
The guiding principles are similar to related proposals from other banking regulators, but will require further clarification through the comment process. On December 2, 2022, the Board of Governors of the Federal...more
On November 16, 2022, the Department of Treasury (“Treasury”) issued a report titled “Assessing the Impact of New Entrant Non-bank Firms on Competition in Consumer Finance Markets” (“Treasury Report”), which, among other...more
The Federal Reserve is taking measured steps to better understand the types of cryptoasset-related activities contemplated by its supervised banking organizations. On August 16, 2022, the Board of Governors of the...more
Key Takeaways: ..On August 13, 2021, FINRA issued Regulatory Notice 21-29 (“RN 21-29”) to remind member firms that they must establish and maintain an adequate supervisory system, including written supervisory procedures...more
When the calendar turned to 2020, my first thought was about how futuristic the year sounded and what kind of interesting things it had in store. At that time, no one could possibly have imagined that some of those...more
SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more
The Financial Industry Regulatory Authority published its 2019 Report on Examination Findings and Observations (2019 Report) on October 16, 2019. This marks the third annual report of FINRA findings, but in a departure from...more
Last week, the Financial Crimes Enforcement Network (FinCEN) and its regulatory partners issued a joint statement in an effort to increase transparency around risk-focused Bank Secrecy Act/anti-money laundering supervision....more
The US Board of Governors of the Federal Reserve System issued proposed guidance for comment that would clarify supervisory expectations related to risk management for large financial institutions. This proposed guidance...more
On Jan. 5, 2016, the Financial Industry Regulatory Authority (“FINRA”) issued its annual Regulatory and Examination Priorities Letter (“2016 Examination Letter” or “Letter”), along with a press release from FINRA chairman and...more
On January 5, the Financial Industry Regulatory Authority released its Regulatory Examination Priorities Letter, which identified its three main areas of focus for the year: (1) Culture, Conflicts of Interest and Ethics; (2)...more
The recently issued 2016 Regulatory and Examination Priorities Letter discloses FINRA’s new initiatives on market integrity and firm culture and reflects a focus on firms’ supervision regarding conflicts of interest and...more
2016 has arrived and, with the new year, FINRA has published its agenda of key examination priorities. This year’s 13-page Regulatory and Examination Priorities Letter sets forth both long-standing and new items for firms to...more
On December 3, 2015, the Office of the Comptroller of the Currency (“OCC”) provided updated guidance for its risk assessment system (“RAS”). The guidance (i) clarifies the relationship between RAS and the Uniform Financial...more
The Board of Governors of the Federal Reserve System (“Board”) in December 2012 issued a proposed rule under the Dodd-Frank Act (“DFA”) for the enhanced supervision of foreign banking organizations (“FBOs”) and any foreign...more