On October 24, 2023, the Board of Governors of the Federal Reserve Board, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the Agencies) approved long-awaited final...more
Agencies Issue Final Guidance on Third-Party Risk Management -
On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more
6/12/2023
/ Algorithms ,
Artificial Intelligence ,
Automation Systems ,
Banking Sector ,
Bots ,
Capital Formation ,
CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
FDIC ,
Federal Reserve ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
FinTech ,
Liquidity ,
OCC ,
Policies and Procedures ,
Private Investment Funds ,
Proposed Rules ,
Publicly-Traded Companies ,
Risk Management ,
Swap Dealers ,
Swaps ,
Third-Party Relationships ,
Third-Party Risk
Regulatory Developments -
Overdraft Protection Programs: Risk Management Practices -
On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more
5/1/2023
/ Banking Sector ,
Banks ,
Broker-Dealer ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Duty of Care ,
ECOA ,
Enforcement Actions ,
FDIC ,
Financial Services Industry ,
FSOC ,
FTC Act ,
Investment Adviser ,
New Guidance ,
OCC ,
Overdraft Fees ,
Redlining ,
Regulation BI ,
Risk Management ,
Section 5 ,
Unfair or Deceptive Trade Practices
On February 9, the Federal Reserve released its hypothetical scenarios for its 2023 bank stress tests, and on February 10, the OCC also released hypothetical economic and financial market scenarios to be used by covered...more
2/17/2023
/ Amended Regulation ,
Banks ,
Blockchain ,
Buy Now Pay Later (BNPL) ,
Commercial Loans ,
Consumer Financial Protection Bureau (CFPB) ,
Custody Rule ,
Disclosure Requirements ,
Dodd-Frank ,
Enforcement Actions ,
Federal Reserve ,
NYDFS ,
OCC ,
RESPA ,
Securities and Exchange Commission (SEC) ,
Security-Based Swaps ,
Stress Tests
Regulatory Developments -
Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial Risks -
On December 2, the Federal Reserve announced that it...more
12/12/2022
/ Broker-Dealer ,
Climate Change ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Federal Reserve ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Initial Public Offering (IPO) ,
Investment Adviser ,
Military Service Members ,
Nasdaq ,
NYSE ,
OCC ,
Payment Systems ,
Preemption ,
Proposed Regulation ,
Public Comment ,
Pump and Dump ,
Regulation S-ID ,
Risk Management ,
Servicemembers Civil Relief Act (SCRA) ,
Truth in Lending Act (TILA)
Regulatory Developments -
CFPB Issues Guidance on Investigation Practices by Consumer Reporting Agencies -
On November 22, the DOL announced a final rule under the Employee Retirement Income Security Act (ERISA) to...more
12/2/2022
/ Coronavirus/COVID-19 ,
Credit Reporting Agencies ,
Credit Reports ,
Cryptoassets ,
Department of Labor (DOL) ,
Employee Benefits ,
Employee Retirement Income Security Act (ERISA) ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Fiduciary Duty ,
Financial Industry Regulatory Authority (FINRA) ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investment Management ,
OCC ,
Retirement Plan
Regulatory Developments -
Federal Reserve and FDIC Solicit Public Comments on Proposed Rulemaking Addressing Large Banks’ Financial Stability -
On October 14, the Federal Reserve and the FDIC published for public...more
Regulatory Developments -
OCC Solicits Research on Implications of Financial Technology for Banking -
On July 25, the OCC is seeking academic and policy-focused research on the impact that fintech and non-bank...more
7/29/2022
/ Accounting Standards ,
Banking Sector ,
CFTC ,
Climate Change ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptoassets ,
Debt Collection ,
FASB ,
FDIC ,
Financial Services Industry ,
FinTech ,
Guidance Update ,
Insider Trading ,
NPRM ,
OCC ,
Public Comment ,
Request For Information ,
Risk Assessment ,
Securities and Exchange Commission (SEC)
Regulatory Developments -
OCC Acting Comptroller Issues Statement on Standards for Stablecoins -
On April 27, Acting Comptroller of the Currency Michael J. Hsu issued a statement regarding stablecoin standards after his...more
5/6/2022
/ Banking Sector ,
Choice of Entity ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
Ethics ,
Financial Industry Regulatory Authority (FINRA) ,
Material Nonpublic Information ,
OCC ,
Phishing Scams ,
Popular ,
Securities and Exchange Commission (SEC) ,
Stablecoins
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed rules to include certain significant market participants as “dealers” or “government securities dealers” to essentially eliminate the trader exclusion...more
4/1/2022
/ Bank Merger Act ,
Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Ratings ,
Cyber Attacks ,
Cyber Threats ,
Cybersecurity ,
Examination Procedures ,
FDIC ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
Market Participants ,
Mergers ,
New Rules ,
Notification Requirements ,
OCC ,
Proposed Amendments ,
Proposed Rules ,
Regulation M ,
Request For Information ,
Reverse Mergers ,
Securities and Exchange Commission (SEC) ,
Securities Dealers ,
Securities Regulation ,
Securities Transactions ,
Special Purpose Acquisition Companies (SPACs) ,
UDAAP
In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more
2/18/2022
/ Augmented Reality ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
Derivatives ,
FDIC ,
Federal Reserve ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment Firms ,
Investors ,
OCC ,
OMB ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Reporting Requirements ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Stress Tests ,
Virtual Reality ,
Whistleblower Protection Policies ,
Whistleblowers
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more
2/11/2022
/ Appraisal ,
Banking Sector ,
Beneficial Owner ,
Borrowers ,
Comment Period ,
Community Development ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Transparency Act ,
Cyber Attacks ,
Cyber Threats ,
Cybersecurity ,
Dodd-Frank ,
Fair Lending ,
FDIC ,
Federal Reserve ,
Federal Savings Associations ,
Financial Services Industry ,
FinCEN ,
FinTech ,
Investment Adviser ,
Investment Companies ,
Lenders ,
New Rules ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Policies and Procedures ,
Private Funds ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Reporting Requirements ,
Risk Management ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
State Savings Associations ,
Valid When Made Doctrine
In This Issue. Acting Comptroller of the Currency Michael J. Hsu discussed the importance of regulation in the crypto space; and the Office of the Comptroller of the Currency (OCC) and the Consumer Financial Protection Bureau...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more
12/17/2021
/ 10b5-1 Plans ,
AML/CFT ,
Bank Secrecy Act ,
Banking Sector ,
Chief Compliance Officers ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Electronic Fund Transfer Act ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Insider Trading ,
Investment Company Act of 1940 ,
Investment Funds ,
Money Market Funds ,
OCC ,
Policies and Procedures ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Regulation E ,
Regulatory Agenda ,
Reporting Requirements ,
Request For Information ,
Risk Management ,
Rule 2a-7 ,
Rulemaking Process ,
SBS Entities ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Security-Based Swaps ,
Stock Repurchases ,
Swap Dealers ,
Trading Plans
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
12/10/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Amended Rules ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
CFTC ,
Comment Period ,
Continuing Education ,
Coronavirus/COVID-19 ,
Corporate Transparency Act ,
FDIC ,
FFIEC ,
Final Rules ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
FinCEN ,
Foreign Corporations ,
Libor ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Proposed Rules ,
Public Comment ,
Real Estate Transactions ,
Recordkeeping Requirements ,
Registration Requirement ,
Regulation Z ,
Reporting Requirements ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC)
In This Issue. The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Board of Governors of the Federal Reserve System (together, the Agencies) issued a final rule...more
12/6/2021
/ Banking Sector ,
Board of Directors ,
Broker-Dealer ,
Cryptocurrency ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Security ,
Digital Assets ,
Disclosure Requirements ,
Electronic Records ,
Final Rules ,
Joint Statements ,
Lenders ,
MSBSPs ,
New Rules ,
Notification Requirements ,
OCC ,
Proposed Rules ,
Proxy Contests ,
Public Comment ,
Recordkeeping Requirements ,
Reporting Requirements ,
SBSD ,
Securities and Exchange Commission (SEC) ,
Shareholder Meetings ,
Shareholder Votes ,
Venture Capital
In This Issue. The U.S. Securities and Exchange Commission (SEC) published a sample comment letter on climate change disclosures; the Financial Industry Regulatory Authority (FINRA) is conducting a review of brokerage firm...more
9/24/2021
/ Banking Sector ,
Broker-Dealer ,
Business E-Mail Compromise (BEC) ,
Climate Change ,
Community Development Financial Institution (CDFI) ,
Corporate Social Responsibility ,
Cybersecurity ,
Depository Institutions ,
Disclosure Requirements ,
FDIC ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
Influencers ,
Investment Adviser ,
Investment Firms ,
Investors ,
OCC ,
OTCBB ,
Policies and Procedures ,
Popular ,
Publicly-Traded Companies ,
Sanctions ,
SEC Comment Letter Process ,
Securities and Exchange Commission (SEC) ,
Social Media
In This Issue. The federal bank regulatory agencies requested public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships; the Office of the Comptroller of...more
7/30/2021
/ Banking Sector ,
Climate Change ,
Comment Period ,
Cross Trading ,
Disclosure Requirements ,
FDIC ,
Fees ,
Fiduciary Duty ,
Financial Services Industry ,
Fixed Income Investments ,
Investment Adviser ,
OCC ,
Policies and Procedures ,
Proposed Guidance ,
Public Comment ,
Registered Investment Advisors ,
Regulatory Agencies ,
Risk Alert ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Third-Party Risk