On April 21, 2023, the Financial Stability Oversight Council ("FSOC") issued two important proposals regarding the designation of a nonbank financial firm as a systemically important financial institution ("nonbank SIFI")...more
Is my money safe? It's a question that we haven't heard very much in over twelve years.
Most businesses and people have no experience with troubled banks and potential bank failures....more
As described in DWT's October 2021 post, the Corporate Transparency Act ("CTA"), enacted as part of the Anti-Money Laundering Act of 2020, establishes beneficial ownership reporting requirements for a broad range of entities...more
In July, we discussed the federal banking agencies' proposal to harmonize their respective risk management guidance. At the time, we highlighted three passages from the proposal that relate to the due diligence banking...more
Last week, the federal banking agencies—Federal Reserve Board (Board), Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC)—issued proposed interagency guidance ("Proposal") on...more
Update April 3: The Small Business Administration (SBA) issued an Interim Final Rule (IFR) earlier today implementing the Paycheck Protection Program (PPP). The IFR has a 30 day comment period (from the date of publication in...more
There has been an unprecedented wave of consolidation in the U.S. payment processing industry this year, with two major core processors acquiring the two largest merchant acquirers, and two of the largest remaining payment...more