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In June 2025, the ABA held its annual Risk and Compliance Conference. The conference heavily focused on how banks are leveraging AI to support front-, middle-, and back-office functions. Conference participants noted that...more
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 April 14, the OCC released a letter providing more details on the recent security breach involving its email systems. The breach — identified as a major incident under the Federal Information Security Modernization Act...more
The Prudential Regulation Authority has published a Dear CEO letter outlining its supervisory priorities for 2025 for domestic banks and international banks and large investment firms. The PRA's key areas of focus for 2025...more
In all our work with clients, my evaluation and expectations around compliance readiness come down to one point: Governance. This can mean a variety of things when it comes to a compliance program, but overall, we boil it...more
The growth in partnerships between banks and Fintech companies through Banking as a Service (BaaS) models presents significant opportunities for innovation across the financial services sector. However, these collaborations...more
The federal banking agencies have jointly issued a final rule that will modify how examiners assess compliance with the Community Reinvestment Act (CRA). Among other changes to the CRA regulations announced on October 24, the...more
Please join Consumer Financial Services Partner Chris Willis and his colleagues Ron Raether and Kim Phan, partners in our Privacy + Cyber Practice Group, as they discuss recent privacy and data security updates in the...more
On November 18, 2021, the Federal Reserve, Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) approved a new final rule regarding reporting of cyber incidents for U.S. banks...more
Letter from Our Co-Chairs - As the digital transformation of financial markets accelerates at breakneck speeds, fintech presents significant opportunities and challenges for both investors and innovators around the world. ...more
As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an...more
A new bill introduced by House Financial Services subcommittee Chairman Rep. Blaine Luetkemeyer would significantly change data security and breach notification standards for the financial services and insurance industries. ...more
The New York Department of Financial Services has adopted detailed cybersecurity regulations for financial institutions. (Here). The NYDFS has filled a vacuum created by the failure of the federal government to act in this...more
On May 15, 2017, the Federal Reserve Office of Inspector General – which also oversees the CFPB – released a report finding deficiencies in the CFPB Office of Enforcement’s (Enforcement) processes for securing sensitive...more
In December 2016, Thomas Curry, the Comptroller of the Currency, stated that cybersecurity was the single greatest systemic threat to our financial system. He was not being hyperbolic. Cybersecurity should be on...more
On March 3, 2016, the BakerHostetler Financial Services industry team held its inaugural Financial Services Risk Summit. The speakers and panels addressed several key areas affecting the financial services sector: regulatory...more
Earlier this summer, the Federal Financial Institutions Examination Council (FFIEC) released its highly anticipated Cybersecurity Assessment Tool (Assessment), which is designed to assist financial institutions in identifying...more