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The Drawbacks Of Banking Regulators' Merger Review Plans

The Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency recently announced proposals to update their approaches to evaluating bank mergers and other business combinations under the Bank Merger...more

A Look At The Feds' Extraordinary Reaction To SVB Collapse

On Sunday evening, the U.S. Department of the Treasury, Federal Reserve, and the Federal Deposit Insurance Corporation announced measures to (1) prevent losses to all depositors — including all uninsured depositors — after...more

Treasury, Federal Reserve, and FDIC Take Actions to Protect Bank Depositors and Support Bank Liquidity to Conduct Operations

On Sunday evening, the Department of the Treasury (Treasury), Federal Reserve, and the Federal Deposit Insurance Corporation (FDIC) announced measures to (1) prevent losses to all depositors—including all uninsured...more

Flurry of Announcements by the Federal Reserve on Crypto Activities

A flurry of activity on January 27 signaled continued skepticism from the Federal Reserve of crypto-asset-related activities generally and open, public or decentralized networks in particular....more

Prudential Regulators Issue New Guidance on Crypto-Assets

On January 3, the Board of Governors of the Federal Reserve (FRB), Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) issued a Joint Statement on Crypto-Asset Risks to Banking...more

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

Federal Reserve Announces Commercial Paper Funding Facility

In a significant move to provide liquidity to U.S. corporations, the Federal Reserve Board announced today that it will establish a Commercial Paper Funding Facility (“CPFF2020”). The Federal Reserve’s action parallels its...more

Governor Cuomo Proposes Significant Expansion of Powers of New York Department of Financial Services

In legislative language accompanying his proposed budget, New York Governor Andrew M. Cuomo proposes to significantly expand the powers of the New York Department of Financial Services (DFS), the state’s banking and insurance...more

Federal Regulators Clarify Bank CIP Obligations for Prepaid Cardholders

Banks and credit unions that issue reloadable, general purpose prepaid cards must apply Customer Identification Program (CIP) procedures to those cardholders, according to guidance issued by the federal banking regulators and...more

OCC Revises CMP Policy

For the first time in over twenty years, the Office of the Comptroller of the Currency (OCC) has formally changed its policy governing civil money penalties (CMP) against national banks, federal savings associations, federal...more

OCC Proposes Recovery Plans for Large Banks

On December 17, 2015, the Office of the Comptroller of the Currency (OCC) proposed guidelines establishing enforceable standards for recovery planning by certain large national banks, federal savings associations and insured...more

CFPB Issues Final Rule to Improve Information About Access to Credit in the Mortgage Market

On October 15, 2015, the Consumer Financial Protection Bureau (CFPB) issued a final rule to implement amendments to the Home Mortgage Disclosure Act (HMDA) made by the Dodd-Frank Wall Street Reform and Consumer Protection...more

Department of Defense Issues Final Rule Expanding Military Lending Act to Credit Cards and Other Consumer Lending Products

On July 21, 2015, the U.S. Department of Defense (“DOD”) announced the final rule amending the Military Lending Act’s (“MLA”) implementing regulations. The changes apply the MLA’s strict lending restrictions to consumer...more

Treasury Department Issues Comprehensive Assessment of US Money Laundering and Terrorist Financing Risk

For the first time in a decade, the Treasury Department has released its own anti–money laundering (AML) and terrorist financing Risk Assessments, which may both set a strategic framework for future AML regulatory...more

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