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The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...more
Nearly 14 years ago, guidance was provided by federal regulators to facilitate commercial real estate loan work-outs. Rather than ‘extend & pretend,’ regulators had encouraged, and are encouraging, banks to work with...more
On April 17, 2023, the Wolfsberg Group (the "Group") issued updated guidelines for financial institutions ("FI") relating to Anti-Bribery and Corruption ("ABC") Compliance Programs. Although the guidance is not binding, it...more
Senators Inquire about CFPB’s Fintech Agenda - On July 27, 2021, Senator Sherrod Brown, the Chairman of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, sent a letter to the Consumer Financial Protection...more
HUD, VA, and USDA Coordinate Extensions of COVID-19 Relief for Homeowners - The U.S. Department of Housing and Urban Development (HUD), the U.S. Department of Veterans Affairs (VA), and the U.S. Department of Agriculture...more
In this Issue. The U.S. Securities and Exchange Commission (SEC) was very active this week, having (i) issued no-action relief allowing registered funds to engage in self-custody of interests in loans that are originated,...more
This edition of the Update addresses: 1. Recent legal and regulatory developments which relate to licencing and regulatory relief, consumer protection, financial markets, anti-money laundering and capital and prudential...more
The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department recently issued clarifications of requirements for Customer Due Diligence (CDD) under the Customer Due Diligence Requirements for Financial...more
On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) published updated guidance intended to “enhance the availability of financial services” for the hemp industry (the Guidance). Even though the Agriculture...more
On September 12, 2018, the Office of the Comptroller of the Currency (the “OCC“) released its first update to the “Deposit-Related Credit” booklet of the Comptroller’s Handbook (the “DRC Booklet“) since its March 2015...more
The Office of the Comptroller of the Currency (“OCC”) has recently updated its “Business Combinations” booklet, which is part of the Comptroller’s Licensing Manual. The revised booklet replaces the prior version, which was...more
The CFPB sent industry trade groups a letter on October 1, 2015 to address the approach of the Federal Financial Institutions Examination Council (FFIEC) member agencies during the initial months following the implementation...more