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Husch Blackwell LLP

New Exemption Order Creates More Flexibility and More Considerations with the Customer Identification Program Rule

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By an exemption order dated June 27, 2025, federal prudential regulators have given banks and credit unions some welcomed flexibility when collecting an individual’s or entity’s taxpayer identification number (TIN) during...more

Goodwin

OCC Finalizes “True Lender” Rule

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more

Kilpatrick

Acting Comptroller Explores the Separation of Banking and Commerce

Kilpatrick on

On November 8, Acting Comptroller of the Currency Keith A. Noreika explored how the separation of banking and commerce evolved in the United States and called for a broader discussion of whether the separation continues to...more

Morrison & Foerster LLP

Financial Services Report, Summer 2016

BELTWAY - Every Last Penny Counts - Five federal banking agencies issued a Supervisory Bulletin titled “Interagency Guidance Regarding Deposit Reconciliation Practices” (the “Guidance”). The Guidance outlines...more

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