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
2/7/2025
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Government Efficiency ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Trump Administration
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
6/21/2023
/ Banking Sector ,
Banks ,
BSA/AML ,
Documentation ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
OCC ,
Oversight Duties ,
Reporting Requirements ,
Risk Management ,
Third-Party ,
Third-Party Risk
We start this issue with a big, virtual welcome to our new colleague Maria Earley. Maria joined us last month as a partner in our Financial Services and Fintech Groups. She represents financial services and fintech companies...more
9/15/2021
/ Banking Sector ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FDCPA ,
FDIC ,
Federal Reserve ,
FinCEN ,
FinTech ,
Joe Biden ,
Military Lending Act ,
OCC ,
TCPA ,
True Lender
As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more
6/9/2021
/ Anti-Money Laundering ,
Arbitration ,
Artificial Intelligence ,
Banking Sector ,
Bostock v Clayton County Georgia ,
BSA/AML ,
Carbon Emissions ,
Climate Change ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Cryptocurrency ,
Cybersecurity ,
Department of Education ,
Department of Homeland Security (DHS) ,
Eviction ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
FinCEN ,
FRB ,
FSOC ,
HOLA ,
Landlords ,
Mortgages ,
NYDFS ,
OCC ,
Popular ,
Student Loans ,
TCPA ,
U.S. Treasury
Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...more
3/2/2021
/ Arbitration ,
Banking Sector ,
BSA/AML ,
California Consumer Privacy Act (CCPA) ,
Comptroller ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Convertible Virtual Currencies (CVCs) ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Department of Financial Protection and Innovation (DFPI) ,
Digital Assets ,
Dodd-Frank ,
ECOA ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
False Claims Act (FCA) ,
FDIC ,
Federal Reserve ,
Financial Services Industry ,
FinCEN ,
Interest Rates ,
Interpretive Letters ,
Memorandum of Understanding ,
Military Lending Act ,
Minority-Owned Businesses ,
Mortgages ,
OCC ,
Payday Loans ,
PayPal ,
Preemption ,
Regulation D ,
SAR ,
SCOTUS ,
Small Business ,
State Attorneys General ,
TCPA ,
True Lender ,
Truth in Lending Act (TILA) ,
UK ,
Women-Owned Businesses
Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...more
12/11/2020
/ Arbitration ,
Banking Sector ,
Bitcoin ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Data Breach ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Federal Savings Associations ,
Financial Services Industry ,
FinCEN ,
FinTech ,
FRB ,
Main Street Lending Programs ,
Mobile Payments ,
OCC ,
Private Attorneys General Act (PAGA) ,
SBA ,
TCPA ,
Third-Party Service Provider
Punxsutawney Phil didn’t see his shadow, so we’re expecting an early spring. Maybe that’s why mini-CFPBs are sprouting or expanding on both coasts. Governor Cuomo announced several key measures impacting financial services...more
On January 30, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) approved a final rule (the “Final Rule”) revising the regulations related to the determination of “control” of banks under the...more
On January 30, 2020, five federal agencies (the “Agencies”) proposed amendments to the rules implementing section 13 of the Bank Holding Company Act of 1956 (the “Volcker Rule”) related to the prohibition on investing,...more
According to new guidance released on December 3, 2019, banks are not required to file suspicious activity reports (SARs) on customers solely because they are engaged in the legal growth or cultivation of hemp (“Guidance”)....more
On July 22, 2019, five federal agencies (the “Agencies”) published a final rule (the “Final Rule”), which conforms the regulations implementing the Volcker Rule to statutory modifications provided by Sections 203 and 204 of...more
On May 28, 2019, a Nevada resident, Morgan Rockcoons, was sentenced in the U.S. District Court for the Southern District of California to 21 months in prison for wire fraud and unlicensed money transmission. In connection...more
On April 8, 2019, the federal banking agencies (the “Agencies”) released two proposals (the “Tailoring Proposals”) which, if adopted, would further tailor the approach to supervision of large foreign banking organizations...more
On December 18, 2018, five federal agencies (the “Agencies”) released a proposed rule (“Proposed Rule”) to conform the regulations implementing the Volcker Rule to statutory modifications provided by Sections 203 and 204 of...more
On October 31, 2018, the federal banking agencies released two separate proposals that, if adopted, would create a more consistent tiered approach to large bank supervision – in other words, supervision of banking...more
On October 3, 2018, the five federal agencies tasked with the supervision, examination, and enforcement of Bank Secrecy Act (BSA) and anti-money laundering (AML) requirements for banks (the “Agencies”), issued an interagency...more
BELTWAY -
The Wayback Machine -
Congress passed, and on May 24, 2018, the president signed into law, the Economic Growth, Regulatory Relief, and Consumer Protection Act (S.2155). The law makes significant changes to...more
6/8/2018
/ Arbitration ,
Auto Lease ,
Banking Sector ,
BSA/AML ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
Fair Lending ,
FDCPA ,
FFIEC ,
FinTech ,
GAO ,
General Data Protection Regulation (GDPR) ,
HMDA ,
Securities and Exchange Commission (SEC) ,
SIFMA ,
TCPA
On March 14, 2018, the U.S. Senate passed S. 2155, the “Economic Growth, Regulatory Relief, and Consumer Protection Act.” If enacted into law, S. 2155 would provide modest regulatory relief to regional and community banks,...more
On January 18, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve Board”) announced the approval of proposed revisions to the Annual Report of Foreign Banking Organizations (“FR Y-7”). The...more
Section 13 of the Bank Holding Company Act of 1956, as amended, and its implementing regulations (the “Volcker Rule”) generally prohibit a “banking entity” from engaging in proprietary trading and from investing in,...more
On June 8, 2017, the Financial CHOICE Act of 2017 (the “CHOICE Act”) was passed on a party line vote by the U.S. House of Representatives, with nearly all Republicans voting in support and nearly all Democrats voting against...more
6/13/2017
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Labor (DOL) ,
Dodd-Frank ,
Executive Orders ,
Fiduciary Rule ,
Financial CHOICE Act ,
Financial Regulatory Reform ,
Financial Services Committee ,
FSOC ,
Trump Administration
Sanctions: Will the Trump Administration Stay the Course?
President Trump made many statements during the campaign regarding actions he plans to take to reverse Obama administration sanctions policies. These included...more
3/22/2017
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Reports ,
Cross-Selling ,
Cuba ,
Cybersecurity ,
Encryption ,
Financial Institutions ,
Investment Management ,
Joint Comprehensive Plan of Action (JCPOA) ,
Margin Requirements ,
Myanmar ,
NYDFS ,
Request For Information ,
Robo-Advisors ,
Russia ,
Sanctions ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Sudan ,
Trump Administration
On December 9, 2016, the Board of Governors of the Federal Reserve System (“Federal Reserve Board”) issued SR 16-18, “Procedures for a Banking Entity to Request an Extended Transition Period for Illiquid Funds” (“SR 1618”). A...more
The Board of Governors of the Federal Reserve System (“Federal Reserve”), consistent with its previously announced intention, extended the conformance period with respect to investments in and relationships with covered funds...more