On June 28, 2024, in an effort to bolster financial institutions’ anti-money laundering and countering the financing of terrorism (“AML/CFT”) programs, the U.S. Department of the Treasury’s Financial Crimes Enforcement...more
The Office of the Comptroller of the Currency (“OCC”) recently sought comment on a proposed rule designed to increase the transparency of the standards applicable to the OCC’s review of business combinations (i.e., bank...more
The Federal Deposit Insurance Corporation (“FDIC”) recently published a Federal Register notice seeking public comment on proposed revisions to the FDIC’s Statement of Policy on Bank Merger Transactions (the “SOP”). Relevant...more
The Office of the Comptroller of the Currency (“OCC”) recently sought comment on a proposed rule designed to increase the transparency of the standards applicable to the OCC’s review of business combinations (i.e., bank...more
On November 7, 2023, the Consumer Financial Protection Bureau (“CFPB”) proposed a rule that would allow the CFPB to supervise certain large nonbank companies that provide consumer financial services such as digital wallets...more
On October 24, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together, the “Agencies”) issued a final rule designed to...more
On July 28, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the National Credit Union Administration (the “NCUA”) and the Office of the...more
On July 27, 2023, in an effort to bolster the resilience of the U.S. banking system in the aftermath of recent bank failures and to promote consistency with international banking capital standards, the Federal Deposit...more
On May 28, 2020, the U.S. House of Representatives passed legislation that, if adopted by the Senate and signed into law by the President, would provide considerable relief to borrowers under the Paycheck Protection Program...more
On May 21, 2020, the U.S. Small Business Administration (“SBA”) released a notice informing lenders of how they may collect loan processing fees for eligible loans issued under the Paycheck Protection Program...more
On April 9, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued guidance for banks that wish to participate in the Federal Reserve’s Paycheck Protection Program Lending Facility (the...more
On April 3, 2020, the Small Business Administration (the “SBA”) published its Interim Final Rule (the “Interim Rule”) governing the origination of “paycheck protection loans” under the newly created small business lending...more
On April 9, 2020, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), and the Office of the Comptroller of the Currency (collectively, the “federal banking...more
On April 6, 2020, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Board of Governors of the Federal Reserve System (collectively, the “federal banking agencies”) announced the...more
On March 27, 2020, the President signed into law the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”). While the CARES Act contains a variety of provisions, including, among other things, unemployment...more
On March 24, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued a statement on its supervisory activities (“Statement”) during the unprecedented COVID-19 pandemic. As part of that...more
Over the past two weeks, we have received numerous inquiries from financial institutions on what actions should be taken or considered to address the COVID-19/Coronavirus pandemic. While every bank is different and the...more
3/22/2020
/ Banks ,
Business Continuity Plans ,
Coronavirus/COVID-19 ,
Emergency Management Plans ,
FDIC ,
FFIEC ,
Financial Institutions ,
Infectious Diseases ,
Popular ,
Remote Working ,
Risk Management ,
Workplace Safety
Over the past two weeks, the international markets have been roiling under news that the COVID-19 virus, commonly referred to as the coronavirus, may be spreading. The Board of Governors of the Federal Reserve System (the...more
3/6/2020
/ Business Continuity Plans ,
Capital Markets ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Emergency Management Plans ,
Federal Reserve ,
FFIEC ,
Financial Institutions ,
Financial Markets ,
Interest Rates ,
U.S. Treasury
On October 29, 2019, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the “Federal Banking Agencies”) issued a joint press...more
On October 16, 2019, the Financial Accounting Standards Board (“FASB”) extended the implementation deadline for the current expected credit loss standard (“CECL”) for qualifying entities. The new implementation deadlines are...more
On September 17, 2019, the Federal Deposit Insurance Corporation (the “FDIC”) passed a final rule providing qualifying community banking organizations the ability to opt-in to a new community bank leverage ratio (“CBLR”)...more
9/27/2019
/ Banking Sector ,
Banks ,
Community Banks ,
Consumer Protection Act ,
Dodd-Frank ,
EGRRCPA ,
FDIC ,
Final Rules ,
Financial Institutions ,
Leverage Capital Ratio ,
Opt-In
On September 17, 2019, the Securities and Exchange Commission (the “SEC”) proposed rules that would update the statistical disclosures currently required by Industry Guide 3, Statistical Disclosure by Bank Holding Companies...more
9/24/2019
/ Bank Holding Company ,
Banking Sector ,
Banks ,
Comment Period ,
Disclosure Requirements ,
Financial Reporting ,
Investors ,
Loans ,
Proposed Rules ,
Public Comment ,
Regulation S-K ,
Savings and Loan Companies ,
Securities and Exchange Commission (SEC)
On July 9, 2019, the Board of Governors of the Federal Reserve System (the “FRB”), U.S. Commodity Futures Trading Commission, Federal Deposit Insurance Corporation (the “FDIC”), Office of the Comptroller of the Currency (the...more
8/5/2019
/ Banking Sector ,
Banks ,
CFTC ,
Exemptions ,
FDIC ,
Hedge Funds ,
Investment Opportunities ,
Investment Portfolios ,
Investors ,
OCC ,
Private Equity Funds ,
Proprietary Trading ,
Securities and Exchange Commission (SEC) ,
Volcker Rule
On June 5, 2019, Illinois Governor J.B. Pritzker signed a $40 billion state budget bill into law. Among the various provisions included in the over 300 page budget is a provision providing for the phase-out of Illinois’...more
On Saturday, June 1, 2019, The Illinois General Assembly passed a bill (the “Diversity Disclosure Bill”) requiring most publicly held companies organized or headquartered in Illinois to include detailed demographic diversity...more