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
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
On March 14, 2025, a judge in the U.S. District Court for the District of Maryland declined to grant a temporary injunction to the City of Baltimore and the Economic Action Maryland Fund. The plaintiffs had requested an...more
3/21/2025
/ Bank Secrecy Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Financial Regulatory Reform ,
FinTech ,
Military Lending Act ,
OCC ,
Regulatory Agenda ,
Stablecoins
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
2/21/2025
/ Congressional Review Act ,
Consumer Financial Protection Bureau (CFPB) ,
CRA ,
Executive Orders ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Regulation Z ,
Regulatory Reform ,
Stablecoins ,
Trump Administration
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
2/14/2025
/ CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Enforcement Actions ,
Federal Funding ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OMB ,
Regulatory Agenda
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
8/6/2024
/ AML/CFT ,
Bank Deposits ,
Deposit Insurance ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Joint Statements ,
OCC ,
Request For Information ,
Risk Management ,
Third-Party Relationships
On July 19, 2024, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (the “Agencies”)...more
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
On January 3, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) issued a joint...more
1/13/2023
/ Board of Governors ,
Cryptoassets ,
Decentralized Finance (DeFi) ,
FDIC ,
Federal Reserve ,
Financial Services Industry ,
Fraud ,
Joint Statements ,
Misleading Impressions ,
OCC ,
Risk Management ,
Stablecoins ,
Unfair or Deceptive Trade Practices
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
Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more
7/15/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Arbitration ,
Auto-Dialed Calls ,
BSA/AML ,
CARES Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
CRA ,
Dodd-Frank ,
E-SIGN ,
Fair Lending ,
FASB ,
FDIC ,
Federal Reserve ,
FinCEN ,
FinTech ,
HMDA ,
Interim Final Rules (IFR) ,
Money Market Mutual Fund Liquidity Facility (MMLF) ,
OCC ,
Paycheck Protection Program Lending Facility (PPPLF) ,
Popular ,
Remittance Transfer Rule ,
Request For Information ,
RESPA ,
SPVs ,
TCPA ,
Volcker Rule
On June 25, 2020, five federal agencies (the “Agencies”) finalized 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
7/1/2020
/ ABS ,
Bank Holding Company Act ,
Banks ,
Covered Funds ,
FDIC ,
Federal Reserve ,
Final Rules ,
Foreign Investment ,
OCC ,
SBIC ,
Securities and Exchange Commission (SEC) ,
Venture Capital ,
Volcker Rule
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 April 23, 2019, the Board of Governors of the Federal Reserve System (“Federal Reserve”) released a proposed rule (“Proposed Rule”) to revise regulations related to the determination of “control” under the Bank Holding...more
The Federal Reserve and the FDIC published proposed changes to resolution plan (or “living will”) requirements applicable to U.S. and foreign banking organizations. The regulatory changes are necessary because the 2018...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
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
On Monday, April 4, 2016, the Board of Governors of the Federal Reserve System (“Federal Reserve”) proposed a revision to Form FR Y-7Q to incorporate the capital adequacy standard reporting requirements for foreign banking...more
Under guidance issued on July 16, 2015 by the federal agencies responsible for implementing the Volcker Rule (the “Agencies”) RICs and FPFs need not be treated as banking entities during a seeding period of up to three...more
On June 26, 2014, the Federal Reserve Board (“Board”) published on its website responses to frequently asked questions (“FAQs”) relating to enhanced prudential standards under Section 165 of the Dodd-Frank Act and its...more
On June 12, 2014, the Office of the Comptroller of the Currency (OCC) issued interim procedures for examiners to assess banks’ progress in developing a framework to comply with the requirements of what is commonly known as...more