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
Missouri has enacted the nation’s ninth state commercial finance disclosure law, regulating the providers and brokers of certain commercial financing transactions. Signed by Governor Mike Parson on July 11, 2024, Missouri...more
On August 2, 2024, New Hampshire enacted legislation that significantly revises its Motor Vehicle Retail Installment Sales Act (the “Act”), effective July 1, 2024. Unfortunately, that effective date is not a typographical...more
On August 9, 2024, the US Federal Deposit Insurance Corporation (FDIC) issued an interpretation of the exclusion of automated teller machines (ATMs) and remote service units (RSUs) from the definition of a domestic branch....more
On July 30, 2024, the FDIC proposed revisions to the restrictions on brokered deposits. The revisions would undo many of the key elements of the 2020 revisions, and would dramatically expand the number of deposit brokers and...more
On July 30, 2024, the Federal Deposit Insurance Corporation (FDIC) proposed revisions to the restrictions on brokered deposits (the “Proposal”). The Proposal is intended to strengthen the restrictions to reflect the FDIC’s...more
Join us for the latest episode of Financial Services Focus for a discussion of Federal Reserve Chair Jerome Powell’s recent Humphrey-Hawkins testimony before the House Financial Services Committee and Senate Banking...more
On May 22, 2024, the US federal banking regulators finalized a new set of reporting requirements for bank loans and commitments to fund finance facilities, private credit lenders, and other nonbank financial entities.This...more
On May 16, 2024, the US Supreme Court upheld the constitutionality of the Consumer Financial Protection Bureau’s (“CFPB”) funding structure in a decision that will have significant ramifications on both the CFPB’s rulemaking...more
On May 15, 2024, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments (the “Amendments”) to Regulation S-P under the Securities Exchange Act of 1934 (the “Exchange Act”), which governs the treatment of...more
Join us on the latest episode of Financial Services Focus as Justin Herring, Jeff Taft and Ana Bruder discuss key cyber threats facing the financial services industry, including third-party risks, sophisticated ransomware,...more
On May 6, 2024, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Federal Housing Finance Agency (FHFA) and National Credit Union Administration (NCUA; collectively the...more
5/14/2024
/ Disclosure Requirements ,
Dodd-Frank ,
FDIC ,
FHFA ,
Financial Institutions ,
Financial Services Industry ,
Incentive Compensation ,
NCUA ,
New Rules ,
OCC ,
Regulatory Requirements
Join us for the first episode of Mayer Brown’s Financial Services Focus series. Financial Services Focus will provide updates on the key legal issues affecting financial products across legal disciplines. This podcast series...more
At the end of March, components of the US Federal Reserve System (“FRS” or the “Fed”) prevailed in two lawsuits brought by depository institutions seeking master accounts.1 These decisions have significant implications for...more
On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more
On March 5, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued a Final Rule that would significantly restrict late fees that consumer credit card issuers may charge from $30 or $41, in most cases, to a mere...more
The end of 2023 saw a barrage of major proposals and other actions by US banking regulators. Many of these are contentious issues that have divided regulators and generated significant public controversy. Final proposals of...more
On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more
2/16/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Money Laundering ,
Popular ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On January 26, 2024, the US federal banking regulators announced proposed reporting changes to implement the Basel III Endgame requirements. This may come as a surprise to the many banking organizations and others, who only...more
On December 27, 2023, the US federal banking regulators proposed a new set of reporting requirements for bank loans and commitments to private credit lenders and intermediaries....more
1/17/2024
/ Banking Regulators ,
Banks ,
Creditors ,
FFIEC ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
OCC ,
Proposed Rules ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
On December 21, 2023, the New York Department of Financial Services (“NYDFS”) finalized guidance on how the banks and mortgage institutions it regulates (“New York Institutions”) should manage climate-related financial and...more
1/4/2024
/ Climate Action Plan ,
Climate Change ,
Consumer Financial Products ,
Corporate Governance ,
Environmental Social & Governance (ESG) ,
Financial Institutions ,
Financial Services Industry ,
Internal Controls ,
Mortgages ,
NYDFS ,
Risk Management
On December 27, 2023, the US federal banking regulators proposed reporting requirements for bank loans and commitments to the fund finance sector. This change reflects not only the rapid growth in this sector but also the...more
Mere days before Halloween, California enacted California Senate Bill 666, imposing a set of restrictions on the fees that commercial financers may charge their small business customers. Signed by the governor on October 13,...more
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”) and...more
On July 27, 2023, US federal banking regulators issued proposals to (i) significantly revise the riskbased regulatory capital requirements for certain midsize and larger US banking organizations (the “Capital Proposal”), and...more