News & Analysis as of

Financial Institutions Compliance Dates

Ballard Spahr LLP

Plaintiffs ask for delay in compliance dates for CFPB open banking rule

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The banking plaintiffs in the suit challenging the CFPB’s open banking rule (“Rule”) have asked a federal court to delay the compliance date of the Rule, contending that even though the Trump Administration has said it was...more

Lowenstein Sandler LLP

Compliance Deadlines to Implement Significant Amendments to Regulation S-P Are Fast Approaching: Key Implications for Covered...

On May 16, 2024, the Securities and Exchange Commission (SEC) adopted sweeping amendments to Regulation S-P, which governs the privacy of nonpublic consumer personal and financial information for a broad range of financial...more

Morrison & Foerster LLP

U.S. SEC Extends Compliance Deadline for Recent Amendments to the Customer Protection Rule

On June 25, 2025, the U.S. Securities and Exchange Commission (SEC) voted to extend the compliance deadline for recent amendments to Exchange Act Rule 15c3-3 (the “Customer Protection Rule”) to June 30, 2026. The amendments,...more

Troutman Pepper Locke

CFPB Extends Compliance Dates for Section 1071 Rule Again Amid Ongoing Litigation

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The Consumer Financial Protection Bureau (CFPB or Bureau) published in the Federal Register an interim final rule extending compliance dates for its 2023 small business lending rule under the Equal Credit Opportunity Act...more

McGuireWoods LLP

With Compliance Date for Reg S-P Amendments Looming, Is Your Firm Ready Yet?

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Welcome to “SERC’ling Up,” your resource for staying ahead in today’s fast-evolving financial landscape. This newsletter delivers perspectives on the latest enforcement trends, regulatory updates and high-stakes developments...more

Bass, Berry & Sims PLC

FCC Extends Deadline for TCPA Consent Revocation Rule Compliance by One Year

Bass, Berry & Sims PLC on

On April 7, the Federal Communications Commission (FCC) issued an Order (Extension Order) granting a limited waiver that delays the effective date of certain portions of Section 64.1200(a)(10) of the FCC’s rules by one year –...more

Ballard Spahr LLP

FDIC Further Delays FDIC Insurance Sign Compliance Date for ATMs and Digital Channels

Ballard Spahr LLP on

The Federal Deposit Insurance Corporation (FDIC) is further postponing the compliance date requirements to display the FDIC official digital sign on an insured depository institution’s (IDI) digital channels, as well as on...more

Venable LLP

Fifth Circuit Places Partial Stay on CFPB Small Business Lending Rule Amid Leadership Change

Venable LLP on

The Fifth Circuit Court of Appeals heard arguments in early February challenging the validity of the Consumer Financial Protection Bureau's (CFPB Small Business Lending Rule. The rule is being challenged by various industry...more

Troutman Pepper Locke

CFSA Seeks Clarification from Fifth Circuit of Required Compliance Date for CFPB Payday Loan Rule

Troutman Pepper Locke on

On November 18, the plaintiff trade groups in Community Financial Services Association of America, Ltd.(CFSA) v. Consumer Financial Protection Bureau (CFPB) filed an Opposed Motion for Clarification of Stay Pending Appeal...more

Goodwin

EU Commission Regulations on Digital Operational Resilience: A Reminder That DORA is Less Than Three Months Away and Will Apply to...

Goodwin on

The European Commission’s adoption on 23 October 2024 of the two regulations (Regulations) supplementing the [the Regulation on digital operational resilience for the financial sector Publications Office (europa.eu)] (DORA)...more

BCLP

The EU’s Digital Operational Resilience Act 2022/2554 (DORA)

BCLP on

Long IT sub-contracting chains can make it hard for financial institutions to understand the vulnerabilities in their IT estate and the location of key functions (where these may be located in entities who do not have a...more

Goodwin

FinCEN Adopts Final AML Program Rule for Investment Advisers

Goodwin on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule (the Final Rule) on August 28 that will treat certain investment advisers and exempt reporting advisers as financial...more

Ballard Spahr LLP

CFPB Releases Updated 1071 Filing Instructions Guide

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On August 16, 2024 the CFPB issued an updated 2025 Small Business Lending Filing Instructions Guide (the “Guide”). The Guide provides updated compliance dates that correspond to the new compliance dates....more

Holland & Knight LLP

FinCEN Reference Guide Clarifies Beneficial Ownership Reporting Requirements

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more

Ballard Spahr LLP

CFPB Releases Interim Final Rule Extending 1071 Compliance Dates

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On June 25th, the CFPB issued an interim final rule with a request for public comment extending the compliance dates for the Small Business Lending Rule in light of the Supreme Court’s decision finding the funding structure...more

WilmerHale

NYDFS Finalizes Amendments to Cybersecurity Regulations

WilmerHale on

On November 1, 2023, New York Department of Financial Services (NYDFS or the “Department”) released the finalized revisions (the “Second Amendment”) to 23 NYCRR Part 500 (Part 500) – the most significant modifications to Part...more

Morrison & Foerster LLP - Social Media

N.Y.’s New Cybersecurity Regulations: What Financial Services Companies Need to Know

With corporate data security breaches on the rise, the New York State Department of Financial Services (NYDFS) has adopted rules requiring financial institutions to take certain measures to safeguard their data and inform...more

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