Despite the proliferation of state laws that legalize the cultivation and sale of marijuana, federal law has remained an obstacle to access to the U.S. financial system for marijuana sellers and producers. With penalties...more
A federal court has rejected an attempt by former First Republic Bank employees to recover assets held in a rabbi trust that funded deferred compensation benefits. In Harrington v. Federal Deposit Insurance Corporation, the...more
A federal district judge in Texas has enjoined federal bank regulators from enforcing the recently overhauled Community Reinvestment Act (“CRA”) rules. The injunction was issued on the eve of the first effective date under...more
Operational resilience is the ability of a bank to prepare for, adapt to, and withstand or recover from disruptions. These disruptions flow from external events such as natural disasters, malicious actors, pandemics, or...more
The New York Department of Financial Services (“NYDFS”) has released a comprehensive revision of the cybersecurity requirements for state-regulated financial services firms, including banks and insurance companies. The new...more
The Federal Reserve Board (“FRB”) Inspector General (the “OIG”) has issued a highly critical report regarding FRB supervision of Silicon Valley Bank (“SVB”) in the years preceding the bank’s failure in March 2023. The...more
The FDIC recently sent a warning letter to a fintech firm that made misleading references to the availability of deposit insurance in promotional materials used for various crypto-related products. Unbanked, Inc, which...more