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Recordkeeping Requirements Financial Regulatory Reform

Akin Gump Strauss Hauer & Feld LLP

CFTC Acting Chair Caroline D. Pham Announces CFTC’s 30-Day Enforcement Sprint

On February 25, 2025, the U.S. Commodity Futures Trading Commission (CFTC) released an enforcement advisory regarding the impact of self-reporting, cooperation and remediation in enforcement cases (the “Enforcement...more

Paul Hastings LLP

The CFTC Is “in the Mode to Make Deals” (and Other Updates on the Commission)

Paul Hastings LLP on

Yesterday, Acting CFTC Chairman Caroline Pham created a two-week window to bring “reasonable settlement offers” to the commission. Based on my conversations with her and others, I believe the CFTC is in “deal mode” and is...more

Orrick, Herrington & Sutcliffe LLP

FDIC receives letter from senators to finalize its custodial accounts rule

On January 16, the FDIC received a letter from Sens. Ron Wyden (D-OR) and John Fetterman (D-PA) urging the finalization of a proposed rule to strengthen recordkeeping for custodial accounts. As previously covered by...more

Dinsmore & Shohl LLP

SEC Enforcement Actions Related to Electronic Communications Recordkeeping Failures

Dinsmore & Shohl LLP on

On January 13, 2025 the U.S. Securities and Exchange Commission (SEC) announced settled Administrative Proceedings against three broker/dealers and nine investment advisers related to electronic communications recordkeeping...more

Troutman Pepper Locke

FDIC Extends Comment Period for Proposed Rule on Recordkeeping for Third-Party Deposits

Troutman Pepper Locke on

In a previous post, we discussed the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more

Troutman Pepper Locke

FDIC Publishes Proposed Rule on Recordkeeping for Third-Party Deposits, Opens Comment Period

Troutman Pepper Locke on

We previously posted on the Federal Deposit Insurance Corporation’s (FDIC) notice of proposed rulemaking aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank companies....more

Troutman Pepper Locke

Where the F(BO) is the Money? Part 2 — Adopting the Right Lessons from Synapse

Troutman Pepper Locke on

This is the second of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more

Cadwalader, Wickersham & Taft LLP

The FDIC’s Proposed “Synapse” Rule Affects Deposit Accounts Opened by Fintech Custodians

On September 17th, the Federal Deposit Insurance Corporation ("FDIC") issued a proposed rule entitled “Recordkeeping for Custodial Accounts” with comments due sixty days from the date of publication in the Federal Register...more

Ballard Spahr LLP

FDIC board approves NPRM that would increase recordkeeping for custodial accounts

Ballard Spahr LLP on

On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept those deposits on behalf...more

Ballard Spahr LLP

FDIC Issues Notice of Proposed Regulations for Enhanced Recordkeeping for Third-Party Custodial Accounts

Ballard Spahr LLP on

On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept those deposits on behalf...more

Mayer Brown

FDIC Proposes New Recordkeeping Requirements for Custodial Accounts

Mayer Brown on

On September 17, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed extensive new recordkeeping requirements and other compliance obligations (the “Proposal” ) for certain types of deposit accounts frequently...more

Troutman Pepper Locke

FDIC Proposes New Rule to Strengthen Recordkeeping for Third-Party Deposits

Troutman Pepper Locke on

On September 17, the Federal Deposit Insurance Corporation (FDIC) announced a notice of proposed rulemaking (Proposal) aimed at enhancing recordkeeping for bank deposits received from fintech and other third-party, non-bank...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Third Attempt: Banking Agencies Revive Incentive-Based Compensation Rules for Financial Institutions

The Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Federal Housing Finance Agency (FHFA) and the National Credit Union Administration (NCUA) recently re-proposed rules...more

Perkins Coie

The Corporate Transparency Act: What To Know and Expect Starting January 1, 2024

Perkins Coie on

Beginning January 1, 2024, the Corporate Transparency Act (CTA) will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and...more

Troutman Pepper Locke

NYC Department of Consumer and Worker Protection Proposes Amendments to Debt Collection Rules

Troutman Pepper Locke on

New York City’s Department of Consumer and Worker Protection (NYC DCWP) recently released a notice of proposed amendments to its debt collection rules. The proposed amendments are detailed, lengthy, and include expanded...more

Jones Day

OCC Concludes That National Banks May Provide Cryptocurrency Custody Services

Jones Day on

The OCC sees holding the cryptographic access keys to control and transfer cryptocurrency as an "electronic corollary" of banking's traditional safekeeping methods. On July 22, 2020, the Office of the Comptroller of the...more

Ballard Spahr LLP

Georgia and Colorado Address MLO Temporary Authority to Operate

Ballard Spahr LLP on

Following receipt and consideration of three written comments on proposed rules distributed on November 18, 2019, the Georgia Department of Banking and Finance adopted final rules on December 20, 2019, that establish...more

Cadwalader, Wickersham & Taft LLP

SEC Proposes Significant Amendments to Investment Adviser Solicitation Rule

The Securities and Exchange Commission (the “Commission” or the ”SEC”), on November 4, approved the publication of a substantial release (the “Release”) proposing significant amendments to the rules under the Investment...more

Ballard Spahr LLP

Significant changes to Connecticut consumer finance licensing laws to take effect October 1, 2018

Ballard Spahr LLP on

Significant changes to Connecticut’s licensing laws for consumer financial services providers will take effect on October 1, 2018.  In addition to changes impacting mortgage-related licensees (e.g. mortgage lenders,...more

Broker-Dealer Compliance + Regulation

FAQs about the FINRA Communication Rules

Understanding Financial Industry Regulatory Authority, Inc. Rule 2210, Communications with the Public - What is Rule 2210, and what does it require? - Rule 2210 governs three categories of “communications” by FINRA member...more

Perkins Coie

Financial Services Bulletin: Action At Federal Agencies

Perkins Coie on

Federal Agencies Issue Enhanced Supplementary Leverage Ratio Final Rule for Largest Banking Organizations and Propose Update to Supplementary Leverage Ratio Rule - On Tuesday, April 8, 2014, the Board of Governors of...more

K&L Gates LLP

SEC Delays Municipal Advisor Registration and Record-Keeping Obligations

K&L Gates LLP on

The SEC has stayed the implementation date of its final rules establishing a permanent registration and record-keeping regime for municipal advisors until July 1, 2014. The new rules are required by the Dodd-Frank Wall Street...more

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