In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more
3/14/2022
/ Banking Sector ,
Belarus Sanctions ,
Beneficial Owner ,
Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Digital Assets ,
Economic Sanctions ,
Executive Orders ,
FATF ,
FDIC ,
Financial Action Task Force ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investors ,
Money Laundering ,
OCC ,
Risk Assessment ,
Risk Management ,
Russia ,
Shell Corporations ,
Terrorist Financing ,
U.S. Treasury ,
Virtual Currency
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule to increase market transparency regarding short selling and extended the comment period for its proposed rule requiring reporting on...more
3/4/2022
/ Annual Percentage Rate (APR) ,
Banking Sector ,
Bias ,
Borrowers ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Cyber Attacks ,
Cyber Threats ,
Cybersecurity ,
Disclosure Requirements ,
Federal Reserve ,
Final Rules ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Services Industry ,
Form CRS ,
Interest Rates ,
Lenders ,
Loan Forgiveness ,
Loan Servicer ,
OCC ,
Property Valuation ,
Proposed Rules ,
Public Comment ,
Public Service Loan Forgiveness program (PSLF program) ,
Regulation Best Interest ,
Regulation SHO ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Short Sales ,
Short Selling ,
Student Loans
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. The Board of the Governors of the Federal Reserve (Federal Reserve) proposed a new supervisory framework for certain holding companies engaged in insurance activities; the Consumer Financial Protection Bureau...more
2/4/2022
/ Alternative Trading System (ATS) ,
Annual Reports ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Depository Institutions ,
Federal Reserve ,
Filing Fees ,
Form PF ,
Fund Sponsors ,
Hedge Funds ,
Holding Companies ,
Private Equity Funds ,
Proposed Amendments ,
Proposed Guidance ,
Proposed Rules ,
Public Comment ,
Regulation ATS ,
Securities and Exchange Commission (SEC)
In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more
1/28/2022
/ Borrowers ,
Broker-Dealer ,
Civil Monetary Penalty ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Cross-Border ,
Deposit Insurance ,
Disclosure Requirements ,
Division of Investment Management ,
European Securities and Markets Authority (ESMA) ,
Examination Procedures ,
FDIC ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Fund Distribution ,
Inflation Adjustments ,
Investors ,
Irrevocable Trusts ,
Lenders ,
Marketing ,
Mortgage Servicers ,
New Rules ,
Notice of Proposed Rulemaking (NOPR) ,
Pilot Programs ,
Proposed Rules ,
Public Comment ,
Reporting Requirements ,
Revocable Trusts ,
Securities and Exchange Commission (SEC) ,
Student Loans ,
Suspicious Activity Reports (SARs)
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 Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more
1/7/2021
/ Advisory Opinions ,
Appeals ,
Banking Sector ,
Broker-Dealer ,
Cash Solicitation Rule ,
Community Reinvestment Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Interim Final Rules (IFR) ,
Interpretive Letters ,
Investment Adviser ,
Lenders ,
OCC ,
OCIE ,
Paycheck Protection Program (PPP) ,
Popular ,
Preemption ,
Proposed Rules ,
Recordkeeping Requirements ,
Regulation Z ,
Relief Measures ,
Reporting Requirements ,
Risk Alert ,
Safe Harbors ,
SAR ,
SEC Advertising Rule ,
Securities and Exchange Commission (SEC) ,
Securities Litigation ,
Securities Violations ,
Special Purpose Entities
In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more
10/29/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Amended Rules ,
Bank Secrecy Act ,
Banking Sector ,
CFTC ,
Community Development Financial Institution (CDFI) ,
Comptroller ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Depository Institutions ,
Derivatives ,
FDCPA ,
FDIC ,
Federal Reserve ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Records ,
Financial Services Industry ,
FinCEN ,
FinTech ,
Forbearance Agreements ,
Insured Depository Institutions ,
Inter-Bank Offered Rates (IBORs) ,
Investors ,
ISDA ,
Military Service Members ,
Mortgages ,
OCC ,
Private Investment Funds ,
Proposed Rules ,
Proxy Statements ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Shareholder Proposals ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Travel Rule ,
True Lender ,
Truth in Lending Act (TILA)
SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more
10/8/2020
/ Banking Regulators ,
Banking Sector ,
Borrowers ,
Capital Requirements ,
Change of Ownership ,
Class Action ,
Community Reinvestment Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Current Expected Credit Losses (CECL) ,
Dividends ,
Enforcement Actions ,
Federal Reserve ,
Final Rules ,
Financial Instruments ,
Financial Services Industry ,
Incentive Awards ,
Investment Adviser ,
Investment Companies ,
Investors ,
Mergers ,
New Guidance ,
New Rules ,
NYSE ,
OCC ,
Paycheck Protection Program (PPP) ,
Public Comment ,
Relief Measures ,
Risk Management ,
SBA ,
Securities and Exchange Commission (SEC) ,
Shareholder Approval ,
Shareholders ,
Small Banks ,
Small Business ,
Stock Repurchases ,
Stress Tests ,
Supervision ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Trust Funds ,
Truth in Lending Act (TILA) ,
Unregistered Securities
In the News. The Securities and Exchange Commission (SEC) adopted final rules to update and expand the statistical disclosures that bank and savings and loan registrants must provide to investors for the first time in 30...more
9/17/2020
/ Accredited Investors ,
Amended Rules ,
Anti-Money Laundering ,
Banking Sector ,
Banks ,
Brokers ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Crowdfunding ,
Data Collection ,
Deposit Insurance ,
Disclosure Requirements ,
Disparate Impact ,
Dodd-Frank ,
Extensions ,
Fair Credit Reporting Act (FCRA) ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Filing Fees ,
Final Rules ,
Financial Reporting ,
Financial Services Industry ,
FinCEN ,
Flood Insurance ,
HUD ,
Interim Final Rules (IFR) ,
Investors ,
Leverage Ratio ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Public Comment ,
Qualified Institutional Buyers ,
Relief Measures ,
Savings and Loan Companies ,
Section 1071 ,
Securities and Exchange Commission (SEC) ,
Small Business ,
Temporary Regulations ,
Time Extensions
In This Issue. The Office of the Comptroller of the Currency (OCC) proposed a rule that would establish that a national bank or federal savings association is the “true lender” of a loan if, as of the date of origination, the...more
7/23/2020
/ Banking Sector ,
Board of Directors ,
Board of Governors ,
Comment Period ,
Consumer Complaint Database ,
Consumer Financial Protection Bureau (CFPB) ,
Court of Justice of the European Union (CJEU) ,
Data Privacy ,
Data Protection ,
Digital Assets ,
Enforcement Actions ,
EU ,
EU-US Privacy Shield ,
FDIC ,
Federal Reserve ,
Federal Savings Associations ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
General Data Protection Regulation (GDPR) ,
Interim Final Rules (IFR) ,
International Data Transfers ,
Lenders ,
Loan Agreements ,
Main Street Lending Programs ,
Nonprofits ,
OCC ,
Paycheck Protection Program (PPP) ,
Personal Data ,
Proposed Rules ,
Public Comment ,
Regulation Z ,
Request For Information
In This Issue. The U.S. Supreme Court struck down the single director leadership structure of the Consumer Financial Protection Bureau (CFPB) in a ruling that could have far-reaching implications for the CFPB and other...more
7/6/2020
/ Banking Sector ,
Broker-Dealer ,
CFTC ,
Conflicts of Interest ,
Constitutional Challenges ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Dodd-Frank ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Eviction ,
FDIC ,
Federal Reserve ,
Fees ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Flood Insurance ,
Forbearance Agreements ,
Hemp Related Businesses ,
Investment Adviser ,
Investment Management ,
MNPI ,
OCC ,
OCIE ,
Paycheck Protection Program (PPP) ,
Popular ,
Private Equity Funds ,
Proposed Regulation ,
Removal For-Cause ,
Reversal ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Seila Law LLC v Consumer Financial Protection Bureau ,
Separation of Powers ,
Severability Doctrine ,
Single Director ,
Tenants
In This Issue. The Office of the Comptroller of the Currency (OCC) finalized a rule to strengthen and modernize regulations under the Community Reinvestment Act; the Securities and Exchange Commission (SEC) voted to adopt...more
5/21/2020
/ Amended Rules ,
Banking Sector ,
Broker-Dealer ,
CARES Act ,
Comment Period ,
Community Reinvestment Act ,
Consolidated Audit Trail ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
CSBS ,
Enforcement Actions ,
False Claims Act (FCA) ,
FCC ,
Federal Reserve ,
FHFA ,
Filing Deadlines ,
Financial Services Industry ,
Forbearance Agreements ,
Form CRS ,
Homeowners ,
Interim Final Rules (IFR) ,
Investment Adviser ,
Loan Forgiveness ,
Mortgages ,
National Market System (NMS) ,
New Rules ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Paycheck Protection Program (PPP) ,
Public Comment ,
Qui Tam ,
Regulation Best Interest ,
Regulation D ,
Relief Measures ,
Robocalling ,
SBA ,
Securities and Exchange Commission (SEC) ,
Time-Barred Debt ,
Transparency
In this Issue: Senate Votes to Expand Paycheck Protection Program; FHFA (Finally) Addresses Liquidity Concerns for Mortgage Servicers. Yesterday, the U.S. Senate unanimously passed legislation providing $484 billion in...more
4/24/2020
/ Banking Sector ,
Borrower Protection Programs ,
Borrowers ,
BSA/AML ,
CARES Act ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Fannie Mae ,
Federal Funding ,
Federal Reserve ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Financial Stimulus ,
Freddie Mac ,
HMDA ,
Legislative Agendas ,
Lenders ,
Liquidity ,
Main Street Lending Programs ,
Mortgage Servicers ,
Paycheck Protection Program (PPP) ,
Regulatory Requirements ,
SBA ,
SBA Lending Programs ,
Small Business ,
Startups
In This Issue. Federal and state regulators continued to take action in the wake of the ongoing global outbreak of the coronavirus (COVID-19). As discussed in several Goodwin client alerts, Congress passed, and the President...more
4/6/2020
/ Banking Sector ,
CARES Act ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Data Collection ,
Enforcement Actions ,
Executive Orders ,
Federal Reserve ,
Financial Services Industry ,
Financial Stimulus ,
Governor Baker ,
Paycheck Protection Program (PPP) ,
Public Health ,
Publicly-Traded Companies ,
Relief Measures ,
Remote Working ,
SBA ,
Shareholder Meetings ,
U.S. Treasury ,
Virtual Meetings
In This Issue. The ongoing global outbreak of the coronavirus (COVID-19) continues to grow in scale and scope, creating public health and humanitarian challenges worldwide. Global economies are also being impacted. Federal...more
3/12/2020
/ Banking Sector ,
Banks ,
Business Continuity Plans ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Crisis Management ,
Disclosure Requirements ,
Exemptive Relief ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Foreign Banks ,
Foreign Investment ,
Infectious Diseases ,
Investment Management ,
New Guidance ,
OCC ,
Proposed Rules ,
Public Health ,
Risk Management ,
Securities and Exchange Commission (SEC)
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve Board) approved its long-awaited framework for tailoring enhanced prudential standards for firms with $100 billion or more in assets; the...more
In This Issue. The Securities and Exchange Commission (SEC) adopted a rule permitting most exchange-traded funds that satisfy a set of standardized conditions to operate without the expense and delay of obtaining exemptive...more
In This Issue. The U.S. House of Representatives voted to approve the SAFE Banking Act, which would permit banks to serve cannabis-related businesses in states where it is legal; the Securities and Exchange Commission (SEC)...more
10/3/2019
/ Banking Sector ,
Cannabis Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Labor (DOL) ,
FDIC ,
Financial Services Industry ,
Marijuana Related Businesses ,
Minimum Salary ,
OCC ,
Popular ,
Real Estate Transactions ,
SAFE ,
Securities and Exchange Commission (SEC)
In This Issue. The Consumer Financial Protection Bureau (CFPB) announced its intention to allow the “QM Patch,” which exempts Fannie Mae and Freddie Mac from the full scope of the ability-to-repay/qualified mortgage rule, to...more
EDITOR'S NOTE -
In This Issue. The Securities and Exchange Commission (SEC) and North American Securities Administrators Association (NASAA) explained how state and federal securities laws might apply to fundraising for...more
EDITOR'S NOTE -
Working Weekends and Holidays. While most Americans were enjoying the Independence Day holiday weekend, the Board of Governors of the Federal Reserve System (Federal Reserve), the Office of the Comptroller of...more
7/12/2019
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Banking Sector ,
Call Blocking ,
Consumer Financial Protection Bureau (CFPB) ,
FCC ,
FDIC ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
HMDA ,
HOLA ,
Mutual Funds ,
No-Action Relief ,
OCC ,
Payday Lending Rule ,
Popular ,
Securities and Exchange Commission (SEC) ,
Summary Judgment ,
Volcker Rule
Editor's Note -
Busy Week for the Fed. The Board of Governors of the Federal Reserve System (Federal Reserve) was busy this past week, announcing that it would limit use of the “qualitative objection” in its Comprehensive...more
3/14/2019
/ CCAR ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Department of Labor (DOL) ,
FFIEC ,
Financial Services Industry ,
FSOC ,
Minimum Salary ,
Over-Time ,
Regulation D ,
Servicemembers Civil Relief Act (SCRA) ,
Wage and Hour
Editor's Note -
Good News, Bad News. Key developments in federal securities laws have recently brought both good news and bad news for current and prospective public companies. First, the Securities and Exchange Commission...more