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Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more
On February 7, the FDIC’s Acting Chairman Travis Hill released a letter to FinCEN Director Andrea Gacki conveying support for updates to the Customer Identification Program requirements to align with modern practices. ...more
On January 20, the FDIC appointed Travis Hill as Acting Chairman. In a prepared statement the next day, Hill outlined his agenda to address changes at the Corporation. Among other efforts, he announced a wholesale review of...more
As we begin the 119th Congress, the nation is also preparing for the new administration to take office in just a few weeks. While federal action on digital assets remains a key focus, this week’s Crypto Policy Tracker shifts...more
On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more
On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more
Shinhan Bank America (“Shinhan”), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network (“FinCEN”), Federal Deposit Insurance...more
Recently, several financial technology (“Fintech”) organizations have applied for – and been granted – banking charter licenses. For example, in May 2019, Grasshopper was approved for a charter issued by the Office of the...more
On January 4, 2021, the Office of the Comptroller of the Currency (OCC) issued the latest in a string of interpretative letters on permissible crypto-related activities of national banks and federal savings associations...more
FDIC Modernizes Brokered Deposit Rule and Amends Interest Rate Restrictions - The FDIC has adopted a final rule that establishes new standards for determining whether deposits made through certain kinds of arrangements...more
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
On May 28, 2019, a Nevada resident, Morgan Rockcoons, was sentenced in the U.S. District Court for the Southern District of California to 21 months in prison for wire fraud and unlicensed money transmission. In connection...more
The Financial Crimes Enforcement Network (FinCEN) recently issued guidance consolidating current FinCEN regulations, rulings, and guidance about cryptocurrencies and money services businesses (MSBs) under the Bank Secrecy Act...more
Part 1: Electronic Commerce - This is the first part of a two-part article discussing the regulatory landscape for financial technology as applied to electronic commerce and electronic banking. This article focuses on...more
Editor's Note - In This Issue. The Securities and Exchange Commission (SEC) granted no-action relief for fund boards; the Financial Stability Oversight Council (FSOC) announced the rescission of the “systemically important...more
Earlier this week, the Conference of State Bank Supervisors (CSBS) announced that seven states have agreed to a multi-state compact that standardizes key elements of the licensing process for money services businesses (MSB). ...more
In his remarks at the LendIt Conference in New York, Comptroller of the Currency Tom Curry discussed the special purpose national bank charters to be granted by the OCC to fintech companies and addressed the various...more
"Technology-based products and services are the future of banking and the economy." "What excites me most about the changes occurring in financial services is the great potential to expand financial inclusion, reach...more