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What Does the Dodd-Frank Relief Bill mean for Enhanced Prudential Standards for Foreign Banks?

On May 23, Congress passed a bill to revise Dodd-Frank to reduce regulatory burdens on banks. Just as with the original Dodd-Frank Act, the real work will have to be done by the banking agencies and thus months will have to...more

FFIEC Examination Procedures for the Beneficial Ownership Rule

The FFIEC has updated its BSA/AML manual effective May 5, 2018, to add a section on the new legal entity due diligence requirements and to update the section of the manual on customer due diligence generally. The Fed...more

Customer Due Diligence and FinCEN’s Frequently Asked Questions

As you are aware, FinCEN’s Customer Due Diligence rules are effective in two days. In a nutshell, these rules require banks to obtain and verify the identity of the beneficial owners of new business customers. The rules are...more

How Does the Fed Want to Regulate Foreign Banks?

On March 5, 2018, the Fed’s new Vice Chairman for Supervision, Randal Quarles, spoke at the Institute of International Bankers annual conference. He wanted to express his thoughts on the appropriate regulatory environment for...more

Bank Corporate Governance—Fed lowers Boom on Wells’ Directors

On February 2, 2018, the Fed announced that it issued a consent Cease and Desist order with Wells Fargo—the bank holding company. The Fed’s press release noted that Wells is replacing 4 directors within this year (out of 17...more

October and November Developments

For the first time in my memory, the Congress passed a joint resolution to disapprove a final regulation of a federal agency—in this case the CFPB and the rule was related to arbitration clauses in contracts for consumer...more

Proposed Fed Guidance for Bank Boards of Directors

Yesterday the Fed published a proposed guidance document for its expectations for board of directors of banks. The release only applies to the boards of banks with over $50 billion in consolidated assets, but the intent of...more

Volcker Rule Developments

At the end of last week, the Fed and the other banking agencies issued an interpretation that applied to investments in certain foreign funds by foreign banking organizations that are subject to the Volcker rule. Such banks...more

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