The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more
2/15/2024
/ Bank Merger Act ,
Banks ,
BSA/AML ,
Community Reinvestment Act ,
Department of Justice (DOJ) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Global Systemically Important Banks (G-SIBs) ,
Merger Agreements ,
Merger Reviews ,
OCC ,
Policy Statement ,
Proposed Rules
The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...more
1/11/2024
/ Banks ,
Climate Change ,
FDIC ,
Federal Reserve ,
Final Guidance ,
Financial Institutions ,
Financial Services Industry ,
Joint Statements ,
OCC ,
Risk Management ,
Supervisory Guidance
In Short -
The Situation: Over the course of 2023, the Financial Stability Oversight Council ("FSOC") took steps that increase the risk of nonbank financial companies and financial activities being designated as...more
The September 2023 publication by the U.S. Treasury Department of its Principles for Net-Zero Financing and Investment ("Principles") marks the first time a major U.S. government agency has provided guidance to the financial...more
12/4/2023
/ Banks ,
Climate Action Plan ,
Climate Change ,
Environmental Policies ,
Financial Institutions ,
Financial Regulatory Reform ,
Financing ,
Greenhouse Gas Emissions ,
Infrastructure ,
Investment ,
Net Zero ,
U.S. Treasury
On November 7, 2023, the Consumer Financial Protection Bureau ("CFPB") issued a proposed rule that would grant it supervisory authority over major nonbank technology companies in the consumer digital payments space....more
11/16/2023
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Credit Reports ,
Digital Wallets ,
Electronic Payment Transactions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Mortgage Lenders ,
Nonbank Firms ,
Peer-to-Peer ,
Proposed Rules ,
Regulatory Agencies ,
Regulatory Agenda ,
Regulatory Authority
A major amendment to the New York State Department of Financial Services' cybersecurity regulations establishes affirmative cybersecurity oversight duties and requires companies to report extortion payments to the agency....more
11/16/2023
/ Chief Information Security Officer (CISO) ,
Cybersecurity ,
Cybersecurity Framework ,
Data Protection ,
Extortion ,
Financial Institutions ,
Financial Services Industry ,
Information Technology ,
NYDFS ,
Popular ,
Risk Assessment ,
Third-Party Service Provider
In Short:
The Situation: The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the "Agencies") have proposed rules...more
10/19/2023
/ Banks ,
Borrowers ,
Debt ,
Debt Collection ,
Debt Instruments ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Global Systemically Important Banks (G-SIBs) ,
Lenders ,
OCC ,
Proposed Rules ,
Subsidiaries
Recent Consumer Financial Protection Bureau ("CFPB") guidance reiterates that creditors must provide consumers with accurate and individualized explanations for adverse actions—a task made more difficult by the complexity of...more
10/12/2023
/ Adverse Action ,
Algorithms ,
Artificial Intelligence ,
Consumer Credit Protection ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
ECOA ,
Financial Institutions ,
Financial Services Industry ,
Machine Learning ,
Regulation B
In Short -
The Situation: The Federal Deposit Insurance Corporation ("FDIC") has proposed significant amendments (the "Proposal") to its rule requiring covered insured depository institutions ("CIDIs") to prepare and file...more
An estimated 32.6 million domestic and foreign companies will soon be required to report information about their beneficial owners to the U.S. Treasury. This White Paper describes the new requirements and the steps companies...more
In Short -
The Situation: The federal banking agencies approved a proposal that would implement a "gold-plated" U.S. version of the "Basel III endgame."...more
In Short -
The Situation: The Financial Stability Oversight Council ("FSOC") recently issued a "notification of proposed interpretive guidance" on updated procedures for designating nonbank financial companies as...more
In Short -
The Background: The recent failure of Silicon Valley Bank, the second-largest bank failure in U.S. history, temporarily paralyzed start-ups, public companies, venture firms, private equity firms, and portfolio...more
In Short -
The Situation: The Federal Reserve Board ("Board") has issued a new policy statement ("Policy Statement") imposing limits, including Board approval requirements, on digital asset activities and other novel...more
On September 29, 2022, the Board of Governors of the Federal Reserve System ("Fed") announced that six of the largest U.S. banks will participate in a first-of-its-kind climate scenario analysis program. The Fed will provide...more