Financial Institutions, Threshold Requirements

CFPB Invites Comment on Larger Participant Thresholds

Morgan Lewis on 8/26/2025

The Consumer Financial Protection Bureau has issued advance notices of proposed rulemaking seeking public comment on whether to revise the thresholds that define “larger participants” in key consumer financial industries....more

EMIR 3: ESMA proposes clearing thresholds

A&O Shearman on 4/17/2025

The European Securities and Markets Authority (ESMA) has published a consultation paper setting out draft regulatory technical standards (RTS) amending the RTS on the clearing thresholds (CTs) under the European Markets...more

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M

Ballard Spahr LLP on 10/18/2024

The CFPB, Fed, and OCC have announced that they are increasing exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2025 through December 31, 2025, these exemption thresholds are...more

CFPB adjusts asset-size exemption thresholds for Regulations C and Z

Orrick, Herrington & Sutcliffe LLP on 12/26/2023

On December 18, the CFPB adjusted the asset-size exemption thresholds for Regulation C (as part of the Home Mortgage Disclosure Act) and Regulation Z (as part of TILA), based on a 4.1 percent increase in the average...more

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

Ballard Spahr LLP on 11/15/2023

The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards

Goodwin on 1/18/2023

Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more

Factors to Be Considered by Financial Organizations for an Effective Transactional Monitoring System

Ankura on 9/27/2022

The rising incidence of financial crime continues to haunt financial institutions globally. As per a recent industry report, more SARs (suspicious activity reports) were filed by ~80% of the firms in 2021. COVID-19 pandemic...more

CFPB Issues Reminder of New Threshold for Reporting HMDA Open-End Lines of Credit Data

Goodwin on 11/22/2021

In This Issue. The Consumer Financial Protection Bureau (CFPB) reminded institutions of a new threshold for reporting Home Mortgage Disclosure Act data about open-end lines of credit; the Financial Crimes Enforcement Network...more

Mexico’s CNBV updates remote contracting requirements

White & Case LLP on 10/12/2021

On Thursday, September 9, the resolutions that reform, add and repeal the general rules on the prevention and identification of operations with resources of illicit origin applicable to financial cooperative associations...more

Regulatory update to remote onboarding procedures of various financial institutions

White & Case LLP on 10/6/2021

On Thursday, September 9, the resolutions that reform, add and repeal the general rules on the prevention and identification of operations with resources of illicit origin applicable to financial cooperative associations...more

2020 HMDA Guide Issued

Ballard Spahr LLP on 2/14/2020

The Federal Financial Institutions Examination Council (FFIEC) recently issued the 2020 edition of the Guide to HMDA Reporting: Getting It Right! (2020 Guide)....more

CFPB proposes amendments to remittance rule

Ballard Spahr LLP on 12/9/2019

The CFPB has proposed several amendments to its remittance rule. Comments on the proposal must be filed no later than January 21, 2020. The proposed amendments are...more

Thresholds Increase for the Major Assets Prohibition of the Depository Institution Management Interlocks Act Rules

Orrick - Finance 20/20 on 10/23/2019

On October 10, the Office of the Comptroller of the Currency (OCC) published a final rule in the Federal Register that increases the major assets prohibition thresholds for management interlocks in the OCC’s rule implementing...more

Federal Banking Agencies Increase Transaction Value Appraisal Exemption

Ballard Spahr LLP on 10/1/2019

As we previously reported, last November the FDIC, Federal Reserve Board and Comptroller of the Currency (the federal banking agencies) proposed a rule to implement a rural residential property appraisal exemption under the...more

Federal Reserve Proposes To Clarify Bank Control Rules

Herbert Smith Freehills Kramer on 6/4/2019

Investors that own large stakes in a bank can trigger the Federal Reserve’s oversight if they have “controlling influence” over the bank. ...more

FinCEN, OCC and FBI Offer Diverging Views on AML Reform in U.S. Senate Testimony

Ballard Spahr LLP on 12/5/2018

First Post in a Two-Part Series - Late last week, the U.S. Senate Committee on Banking, Housing, and Urban Affairs (the “Banking Committee”) met in open session to conduct a hearing on “Combating Money Laundering and Other...more

Dodd-Frank Rollback Benefits Insurers

Carlton Fields on 10/4/2018

Marketing Private Life Insurance Separate Accounts to Smaller Banks - Subject to certain exceptions, the so-called “Volcker rule” provisions of the Dodd-Frank Act and regulations thereunder (collectively, the Volcker Rule)...more

Dodd-Frank Revisions Benefit Private Companies: Congress Doubles Enhanced Disclosure Trigger for Equity Compensation Awards Under...

Ward and Smith, P.A. on 8/31/2018

The Economic Growth, Regulatory Relief, and Consumer Protection Act (the "Act") hit national news channels in late May 2018 due to its sweeping relief from provisions of the 2010 Dodd-Frank Wall Street Reform and Consumer...more

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