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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

FinReg Currents - Week 11

On April 1, 2025, the House Financial Services Committee issued a press release regarding a number of Committee requests to various federal agencies for rescission, modification, or re-proposal of specific Biden...more

FinReg Currents - Week 5

On February 18, 2025, President Trump signed an Executive Order designed to reduce the power of federal independent agencies by bringing them under the purview of the White House. The Executive Order provides that it applies...more

FinReg Currents - Week 4

On February 7, 2025, newly confirmed Office of Management and Budget (OMB) director Russell Vought replaced Treasury Secretary Scott Bessent as acting director of the CFPB....more

FinReg Currents - Week 3

Each week of the first 100 days of the new Trump Administration, we will publish updates on key federal financial services regulatory and related developments. This week, we review the following developments as of Wednesday:...more

Banking Agencies Address Banking Arrangements with Third Parties to Provide Deposit Products and Services

On July 25, 2024, the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the “Agencies”) issued a joint statement to banks regarding risks...more

OCC Issues Guidance on Venture Lending

On November 1, 2023, the Office of the Comptroller of the Currency (OCC) issued detailed guidance (the Bulletin) to national banks and federal savings associations addressing risk management standards and safe and sound...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

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