News & Analysis as of

Third-Party Financial Institutions

Morrison & Foerster LLP

Crypto-Asset Safekeeping: What’s Involved If You’re a Bank (or if You Want to Be One)

On July 14, 2025, the federal banking agencies issued a joint statement to clarify regulatory expectations for banking organizations that provide or are considering providing safekeeping for crypto-assets (“Joint Statement”)....more

Ropes & Gray LLP

Pixel Litigation Risk at Financial Institutions

Ropes & Gray LLP on

An increasingly aggressive plaintiffs’ bar has brought purported class action suits based on the nearly ubiquitous use of tracking technologies used for website analytics. Although any actual harm to the plaintiffs is...more

McGlinchey Stafford

FinCEN Order Allows Banks to Collect Taxpayer Information from Third Parties

McGlinchey Stafford on

In a significant move, on June 27, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order granting banks and their subsidiaries an exemption from the Customer Identification...more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

On June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more

Husch Blackwell LLP

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

Husch Blackwell LLP on

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

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

Integreon

DORA Compliance Part 1: Proactively Meeting DORA Supply Chain Resilience Obligations

Integreon on

Introduction to DORA and its Implications - As of Jan.17, 2025, the European Union’s Digital Operational Resilience Act (DORA) became enforceable. This new regulatory framework significantly impacts financial institutions and...more

Bracewell LLP

FINRA Facts and Trends: February 2025

Bracewell LLP on

Welcome to the latest issue of Bracewell’s FINRA Facts and Trends, a monthly newsletter devoted to condensing and digesting recent FINRA developments in the areas of enforcement, regulation and dispute resolution. We dedicate...more

Walkers

A comprehensive guide to the BMA's proposed new Operational Resilience and Outsourcing Code

Walkers on

In response to the increasing interconnectedness of financial service providers across global networks, the BMA is proposing to implement a new Operational Resilience and Outsourcing Code for regulated entities across all...more

K&L Gates LLP

Managing Artificial Intelligence: The Monetary Authority of Singapore's Recommendations on AI Model Risk Management

K&L Gates LLP on

Introduction and Background - On 5 December 2024, as part of the Monetary Authority of Singapore’s (MAS) incremental efforts to ensure responsible use of artificial intelligence (AI) in Singapore’s financial sector, MAS...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 52: Fostering Innovation Through Responsible Regulation

Brandon Milhorn, President and CEO of the Conference of State Bank Supervisors, joins RegFi co-hosts Sherry Safchuk and Jerry Buckley to share his perspective on the challenges facing community banks and the role of...more

Ankura

The Way Out is Through: A Guide for Navigating U.S. Consumer Privacy Laws

Ankura on

It can be daunting for Fintechs, money services businesses (MSBs), and other non-bank entities operating in the consumer financial products and services space to navigate privacy legislation and determine which provisions of...more

BCLP

Managing Technology Supply Chains: What the Advent of the UK’s Critical Third Party Regime Means for Financial Services Firms and...

BCLP on

The FCA, PRA, and Bank of England have published their finalised critical third party (CTP) rules (and accompanying guidance) in PS24/16 Operational resilience: Critical third parties to the UK financial sector....more

A&O Shearman

UK Regulators Finalize Rules on Critical Third Parties to the UK Financial Sector

A&O Shearman on

The Prudential Regulation Authority and Financial Conduct Authority have published a joint policy statement on operational resilience for critical third parties (CTPs) in the U.K. financial sector, which includes their final...more

Latham & Watkins LLP

UK Regulators Publish Final Rules for Critical Third Parties

Latham & Watkins LLP on

The new regime will take effect on 1 January 2025, but will not diminish the responsibilities of financial services firms relying on the services of critical third parties....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

Baker Botts L.L.P.

New York State Department of Financial Services Issues Guidance Concerning Cybersecurity Risks Posed by Artificial Intelligence

Baker Botts L.L.P. on

Last month, the New York State Department of Financial Services (“DFS”), which has broad regulatory powers over financial services-related entities and insurance companies operating in New York State, published guidance...more

Barnea Jaffa Lande & Co.

Understanding DORA: An Overview of the Digital Operational Resilience Act

The Digital Operational Resilience Act (DORA) is an EU regulatory framework, aimed at enhancing the financial sector’s ability to withstand and recover from ICT (information and communication technology) disruptions....more

A&O Shearman

Zooming In on AI - #6: AI under financial regulations in the U.S., EU and U.K.

A&O Shearman on

Many governments are grappling with the question of how to regulate artificial intelligence to ensure it is adopted safely and used responsibly without hampering innovation. Governments have generally indicated similar...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

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

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

Perkins Coie on

The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...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

McGlinchey Stafford

Bank Partnerships in an Evolving World

McGlinchey Stafford on

Financial institutions have utilized service providers for a multitude of purposes over many years. The use of service providers has not historically been a controversial issue, and financial institutions have always had an...more

K&L Gates LLP

Overview of the CFPB's Proposed Open Banking Rule and Final Industry Standard Setting Rule

K&L Gates LLP on

The financial services and banking industry landscape continues to evolve in the face of new and emerging technologies. This phenomenon is especially prevalent in the sharing of consumer data between financial institutions...more

62 Results
 / 
View per page
Page: of 3

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide