Effective April 1, 2021, the Federal Deposit Insurance Corporation (“FDIC”) launched a “Brokered Deposit” bankers’ resource web page, concurrently with the effective date of its final rule (the “Rule”) to modernize the...more
Readers will recall that in our previous articles concerning the latest developments in money transmittal laws, we noted state regulators’ increasing tendency to enforce their state money transmittal laws on out-of-state...more
The Office of the Comptroller of the Currency (“the OCC”) has issued a Notice of Proposed Rule Making (NPR) to revise and reorganize its regulations relating to the activities and operations of national banks and Federal...more
This QuickStudy is intended to supplement our previous QuickStudy, published on June 17, 2019, regarding the election to be treated as a “covered savings association.” On July 1st, the OCC issued Bulletin 2019-31 (the...more
On May 24th the Office of the Comptroller of the Currency issued its final regulation (“final regulation”) implementing the provisions of the newly created section 5A of the Home Owners’ Loan Act. This new section 5A allows...more
The United States Department of Treasury’s Financial Crimes Enforcement Network’s (FinCEN) new customer due diligence rule released in May has caused concern throughout the industry. In what it says is an effort to prevent...more
Last December we alerted our clients of newly proposed anti-money laundering regulations issued by the New York Department of Financial Services (the Department). These rules generated nationwide attention (and criticism) due...more
Within the last two weeks, the Office of the Comptroller of the Currency issued two bulletins directly related to enforcement matters. OCC Bulletin 2016-5, detailing the OCC’s revisions to its Policies and Procedures Manual...more