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The federal banking regulators have each recently adopted a more permissive approach to the regulation of cryptocurrency activities within the banking sector. The Office of the Comptroller of the Currency (OCC), the Federal...more
CFPB Imposes $5 Cap on Overdraft Fees Charged by Large Banks - The CFPB has adopted a final rule capping overdraft fees at $5 for banks and other depository institutions with more than $10 billion in assets (covered...more
It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in venture lending. On November 1, 2023, the Office of the Comptroller of the Currency...more
Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more
On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more
On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...more
Federal Reserve Policy Aims to Level the Playing Field for Insured and Uninsured Banks: The Federal Reserve has issued a policy statement clarifying that uninsured state member banks will be subject to the same limitations...more
Headlines - ..FDIC Proposes Substantial Increase in Deposit Insurance Assessment Rates ..Federal Reserve Releases New CECL Implementation Tool: Expected Losses ..Estimator OCC Report Highlights Risks Facing the Federal...more
It takes something significant for all the US Banking Regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – to come together to pool...more
Federal Reserve Seeks Comments on Guidelines for Fintechs Receiving Fed Accounts and Services - The Federal Reserve System (the Fed) issued a request for comment on new guidelines for the Fed’s Regional Banks to use when...more
Federal Reserve Issues New Guidance on Managing the LIBOR Transition - The Federal Reserve has issued guidance on how examiners will assess a banking organization’s progress in preparing to transition to a replacement rate...more
In this Issue. The U.S. Department of the Treasury announced that it was opening the application process for the Emergency Capital Investment Program, a new program designed to provide long-term, low-cost equity and...more
Federal Banking Agencies Issue New Guidance on Managing the LIBOR Transition - The member agencies of the Federal Financial Institutions Examination Council (“FFIEC”) have issued joint guidance for banking organizations...more
In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more
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
In This Issue. The Securities and Exchange Commission (SEC) adopted amendments to its exemptive applications procedures under the Investment Company Act of 1940, as amended (the 1940 Act) and proposed to amend Form 13F to...more
On May 27, 2020, the U.S. Federal Reserve (“Fed”) announced additional changes to the Main Street Lending Program (“MSLP”), while also providing additional guidance through an updated FAQ and posting documents for MSLP to the...more
In This Issue. The Small Business Administration (SBA) provided guidance on a borrower’s good faith certification on the necessity of Paycheck Protection Program (PPP) loan requests, announcing a safe harbor regarding this...more
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve) expanded access to its Paycheck Protection Program Liquidity Facility (PPPLF) to non-bank lenders and expanded the collateral eligible to...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule that would establish a revised framework for the fair value determination for purposes of the Investment Company Act of 1940 and have...more
Priming the Pump. As the COVID-19 outbreak continues, the Board of Governors of the Federal Reserve System (Federal Reserve), consistent with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), took additional...more
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
In This Issue. Federal financial regulators brought January to an impactful conclusion last week. On the morning of January 30, five federal financial regulators issued a proposed rule that would fundamentally modify the...more