Starting this June, the first tier of small business lenders will begin collecting certain data to report to the Consumer Financial Protection Bureau under Rule 1071, issued pursuant to Section 1071 of the Dodd-Frank Act....more
On January 24, 2024, the Consumer Financial Protection Bureau (“CFPB”) proposed a new rule, which would expand its crackdown on junk fees. In February 2023, almost a year ago, we wrote about the CFPB’s initial effort to curb...more
On October 3, 2023, the Federal Deposit Insurance Corporation (FDIC) approved proposed guidelines establishing standards for corporate governance and risk management for covered institutions with total assets of $10 billion...more
Digital asset activities of licensed institutions must be approved and will be assessed for potential safety and soundness risks. On December 15, 2022, the New York State Department of Financial Services (NYDFS) issued...more
On September 1, 2021, the Consumer Financial Protection Bureau (CFPB or “Bureau”) issued its long-awaited small business lending data collection proposed rule (“Proposed Rule” or “Proposal”). The Proposed Rule would implement...more
On May 11, 2018, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) implemented its Final Rule on Customer Due Diligence Requirements for Financial Institutions (“Rule”) to amend the scope of...more
Beginning May 11, 2018, the new Financial Crimes Enforcement Network (FinCEN) customer due diligence rule (the “CDD Rule”) will require covered financial institutions to identify, and verify the identity of, the beneficial...more
Long awaited rules for “Customer Due Diligence Requirements for Financial Institutions” (the CDD Rules) went into effect on May 11, 2018. FinCEN has taken steps to clarify and refine implementation of the CDD Rules, issuing...more
Effective May 11, 2018, covered financial institutions are required to comply with the customer due diligence rule (the Rule) that the Financial Crimes Enforcement Network (FinCEN) finalized in May 2016. The Rule mandates the...more
On May 11, 2018, the beneficial ownership rule became fully effective. While the rule was finalized on July 16, 2016, compliance was not mandatory until May 11, 2018. The delay in implementation was to permit covered...more
On October 15, 2015, the CFPB released a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA), requiring certain data on mortgage applications and loans to be collected beginning in 2017...more
The CFPB has published a notice in the Federal Register announcing that it has revised its methodology statement for calculating the average prime offer rates (APORs) under Regulations C and Z. Regulation C requires...more
The federal banking supervisors have jointly published 285 pages of proposed rules on incentive-based compensation practices, as required by the Dodd-Frank legislation enacted in 2010. The proposed rules only apply to banks...more
On May 11, 2016, FinCEN published in the Federal Register its long-awaited anti-money laundering (“AML”) rules (the “Final Rules”) governing corporate entities doing business with banks and other financial institutions that...more
Last month, consistent with their obligation under the Dodd-Frank Act, several federal agencies released for comment a joint proposed rule that would prohibit any incentive compensation that encourages inappropriate risk...more
The Financial Crimes Enforcement Network (FinCEN) on May 11 released its long-awaited Final Rule (CDD Rule) that will require certain financial institutions to “look through” the nominal account holder to identify the...more
Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. ...more
In AML/BSA rule amendments published May 11, FinCEN will require “covered financial institutions” to implement new beneficial-owner identification and verification as part of their Customer Due Diligence (“CDD”) and adopt...more
On May 5, 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued final rules (the Final Rules) on customer due diligence requirements for banks, securities broker-dealers, mutual funds, and...more
As part of the U.S. Treasury Department's ongoing efforts to prevent bad actors from using U.S. companies to conceal money laundering, tax evasion, and other illicit financial activities, the Financial Crimes Enforcement...more
If all goes according to plan, financial institutions will report over 250 million data points related to mortgage loan applications and originations in 2018. If the mortgage market returns to the high volumes seen in 2005,...more
On October 15, 2015, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). At nearly 800 pages, the new HMDA rule changes (i) the...more
On October 15, 2015, the CFPB released a final rule amending Regulation C, 12 C.F.R. part 1003, which implements the Home Mortgage Disclosure Act (HMDA). Like the August 2014 proposed rule, the final rule includes changes to...more
On July 22, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published in the Federal Register a final rule pursuant to Section 311 of the Patriot Act against FBME Bank Ltd. (FBME,...more
Additional guidance issued five weeks before the July 21, 2015 conformance date. On June 12, the five federal agencies jointly responsible for implementing the Volcker Rule (the Agencies) released two new “Frequently...more