On April 18, 2024, the Financial Crimes Enforcement Network (“FinCEN”) announced its revised implementation schedule for providing access to the beneficial ownership information (“BOI”) reports. The tentative, revised...more
At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more
On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more
Matt Bisanz interviews Isaac Boltansky, Director of Policy Research at BTIG, about the risks and regulatory trends for the rest of the year....more
The end of 2023 saw a barrage of major proposals and other actions by US banking regulators. Many of these are contentious issues that have divided regulators and generated significant public controversy. Final proposals of...more
On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more
2/16/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Money Laundering ,
Popular ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On January 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (the “Department”) issued a notice of proposed rulemaking seeking comment on a proposed regulation in response to the Executive Order (E.O.)...more
2/15/2024
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Cloud Computing ,
Comment Period ,
Customer Identification Program (CIP) ,
Cybersecurity ,
Executive Orders ,
Financial Institutions ,
IaaS ,
Machine Learning ,
National Security ,
NPRM ,
Proposed Regulation ,
U.S. Commerce Department
On January 16, 2024, the comment period closed for the US banking regulators’ Basel III Endgame proposal. Nearly 200 comment letters were submitted from the financial sector, commercial user, and the general public....more
On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more
1/17/2024
/ Banking Regulators ,
Banks ,
Creditors ,
FFIEC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OCC ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
On December 21, 2023, the New York Department of Financial Services (“NYDFS”) finalized guidance on how the banks and mortgage institutions it regulates (“New York Institutions”) should manage climate-related financial and...more
1/4/2024
/ Climate Action Plan ,
Climate Change ,
Consumer Financial Products ,
Corporate Governance ,
Environmental Social & Governance (ESG) ,
Financial Institutions ,
Financial Services Industry ,
Internal Controls ,
Mortgages ,
NYDFS ,
Risk Management
On December 27, 2023, the US federal banking regulators proposed reporting requirements for bank loans and commitments to the fund finance sector. This change reflects not only the rapid growth in this sector but also the...more
On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) released a final rule to implement the beneficial ownership information (“BOI”) access requirements of the Corporate Transparency Act (“CTA”) (the...more
12/29/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Popular ,
Regulatory Requirements ,
Reporting Requirements
On October 20, 2023, the US federal banking regulators announced that they were extending the period for public comment to January 16, 2024 for both the (i) Basel Endgame proposal to significantly revise the risk-based...more
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and...more
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and...more
On July 6, 2023, the Basel Committee on Banking Supervision (“Basel Committee”) released proposed revisions to its core principles for effective banking supervision (the “Revised Principles”). The Revised Principles are...more
Banking organizations looking to reduce the amount of risk-based regulatory capital required to support residential mortgage loan portfolios can use synthetic securitization to convert the capital treatment of their exposures...more
Companies will be affected in a variety of ways by the receivership of Signature Bank, Silicon Valley Bank or any other similarly situated financial institution. Companies may face difficulty accessing bank facilities or the...more
3/14/2023
/ Banks ,
Capital Formation ,
Corporate Governance ,
Disclosure Requirements ,
Duty of Care ,
Duty of Loyalty ,
Entire Fairness Standard ,
Financial Institutions ,
Financial Markets ,
Insolvency ,
Investment ,
Liquidity ,
Publicly-Traded Companies ,
Receivership ,
Silicon Valley
On December 15, 2022, the New York Department of Financial Services (“NYDFS”) issued guidance clarifying that all New York banking organizations are required to obtain prior agency approval for virtual currency-related...more
On January 30, 2020, the Board of Governors of the Federal Reserve System (“FRB”), the Federal Deposit Insurance Corporation (“FDIC”), the Office of the Comptroller of the Currency (“OCC”), the Securities and Exchange...more
2/13/2020
/ Banking Reform ,
Banking Regulators ,
CFTC ,
Covered Funds ,
FDIC ,
Financial Institutions ,
Financial Regulatory Reform ,
FRB ,
Loans ,
OCC ,
Proprietary Trading ,
Regulatory Agenda ,
Regulatory Burden ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Securitization ,
Venture Capital ,
Volcker Rule ,
Wealth Management