News & Analysis as of

Credit Unions FinCEN Financial Institutions

Orrick, Herrington & Sutcliffe LLP

Agencies allow banks to access tax ID numbers from third parties

On June 27, the OCC, FDIC and NCUA, with the concurrence of FinCEN, granted an exemption allowing banks to use a third party source to obtain customer tax identification numbers (TIN) for customers before opening an account....more

Ballard Spahr LLP

Financial institutions may rely on third parties for Social Security, Taxpayer Identification Numbers

Ballard Spahr LLP on

Banks and credit unions may now rely on third parties to provide a consumer’s Social Security or Taxpayer Identification Number, according to an order issued by the FDIC, OCC and the NCUA with the consent of the Financial...more

McGlinchey Stafford

What Would Cannabis Rescheduling Mean for Lending and Payments Legality?

McGlinchey Stafford on

The U.S. Drug Enforcement Agency’s proposal to reschedule cannabis from a Schedule I to a Schedule III drug under the Controlled Substances Act (CSA) has generated considerable buzz across business sectors, including for the...more

Troutman Pepper Locke

Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking

Troutman Pepper Locke on

As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more

Carlton Fields

Credit Unions Ask Senate Banking Committee to Make Cannabis Banking Safe

Carlton Fields on

In the latest chapter of the ongoing saga of the U.S. Senate’s consideration and hopeful passage of the Secure and Fair Enforcement (SAFE) Banking Act, on February 7, 2020, the Credit Union National Association (CUNA) sent a...more

Allen Matkins

DBO Issues Guidance To Banks And Credit Unions Serving Cannabis Related Businesses

Allen Matkins on

In the early 1970s, I worked as a petroleum transfer engineer (aka service station attendant). In those halcyon days, we actually pumped the gas for customers, washed their windows and offered to check the oil. I remember one...more

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