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No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Federal Reserve Issues Guidance on Novel Activities, Including Bank-Fintech Partnerships

On August 8, 2023, the Board of Governors of the Federal Reserve System (FRB) issued two Supervision and Regulation Letters (“SR Letters”) that provide guidance on the agency’s supervision of novel activities and the process...more

Banking Agencies Issue Joint Third-Party Risk Management Guidance

On June 9, 2023, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) published final joint guidance on managing...more

FDIC Bank Receivership Frequently Asked Questions - UPDATED 3/20/2023

UPDATE (3/20 PM): Developments Related to Flagstar Bank, SVBB, SVB Financial Group, Credit Suisse, and First Republic Bank- On March 19, 2023, the FDIC announced that the agency has entered into a purchase and...more

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