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Why Financial Institutions Should Stay the Course

Introduction - Many regulated businesses believe that the only thing worse than strict regulations is a wholly uncertain regulatory environment. With many rule changes on hold and enforcement actions and investigations being...more

FinCEN Issues Geographic Targeting Order to Require Certain Money Services Businesses to File CTRs for Smaller Transactions

On 11 March 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) to require money services businesses (MSBs) located in specified zip codes of California and Texas to file currency...more

Lessons From 2024 Anti-Money Laundering Enforcement Actions

In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering (AML), and countering the...more

HUB Talks: The Impact of Overdraft Fees on Banks and Consumers

In this episode, Judie Rinearson and John ReVeal discuss class action litigation and regulatory enforcement concerns arising from overdraft fee disclosures and practices. John also shares his insight about possible...more

More Tools for AML Enforcement and More to Come: Key Considerations from the 2020 Anti-Money Laundering Act and the Corporate...

On 1 January 2021, Congress overrode President Trump’s veto of the National Defense Authorization Act (the NDAA). As part of the NDAA, Congress included long-considered provisions with the potential to revolutionize...more

Trust Companies Face Increased Anti-Money Laundering Requirements

On 15 September 2020, the Financial Crimes Enforcement Network issued final rules to expand the anti-money laundering (AML) obligations of certain banks, trust companies, and credit unions under the Bank Secrecy Act (BSA)....more

The OCC’S ANPR on Digital Banking: Is this a Harbinger for Digital and Open Banking in the US?

The office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) on June 3, 2020, focusing on digital banking activities. Typically such ANPRs are a precursor to new federal...more

6/19/2020  /  Banking Sector , OCC , Open Banking

OCC Issues Final Rule to Fix Madden

On May 29, 2020, the Office of the Comptroller of the Currency (“OCC”) issued a final rule (https://www.occ.gov/news-issuances/federal-register/2020/nr-occ-2020-71a.pdf) to clarify that, when a federal or state-chartered...more

COVID-19: Understanding the Borrower Certification Requirements under the Paycheck Protection Program

BACKGROUND - In order to obtain a Paycheck Protection Program (PPP) loan, Section 1102(G) of the Coronavirus Aid, Relief and Economic Security (CARES) Act, requires that an eligible recipient certify to the following four...more

COVID-19: Emergency Regulations Do Not Pass Constitutional Muster

Federal Judge Enjoins Enforcement of Massachusetts Attorney General’s Debt Collection Ban Under First Amendment - In response to the COVID-19 emergency, the Massachusetts Attorney General’s Office (“AGO”) issued a set of...more

COVID-19: The Massachusetts Attorney General’s Office Issues Emergency Regulations Significantly Limiting Debt Collection in...

The rapid spread of the Coronavirus Disease 2019 (“COVID-19”) has caused unprecedented disruptions to the U.S. economy, both at the state and national levels. On March 10, 2020, the Governor of Massachusetts declared a State...more

COVID-19: UPDATED Q&A for SBA Emergency Loans (Updated)

The following questions and answers are based on Title I to the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act, Pub.116-136, which was signed into law by President Trump on March 27, 2020, as supplemented by...more

COVID-19: Its Impact on Banking, Fintech, and Payments: FAQs

1. Q. The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) implements the disbursement of $1,200 payments of COVID-19 stimulus funds to millions of Americans. How will the current payment system address the...more

COVID-19: Senate Includes SBA "Payroll Protection Package" Loan Relief to Small Businesses in CARES Act

On March 25, 2020, the U.S. Senate unanimously approved another major piece of legislation to address the economic and medical concerns arising from the coronavirus; the Coronavirus Aid, Relief, and Economic Security Act, or...more

COVID-19: UPDATED Q&A for SBA Emergency Loans

On March 22, 2020, Senate Majority Leader McConnell released a draft of the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act, which would amend the Small Business Act (15 U.S.C. Section 636(a)) (“SBA Act”) to...more

COVID-19: Q & A for Small Business Administration (SBA) Emergency Loans

On March 22, 2020, Senate Majority Leader McConnell released a draft of the Coronavirus Aid, Relief, and Economic Security Act, which would amend the Small Business Act to provide emergency loan relief to certain eligible...more

FDIC Proposes Brokered Deposit Relief

On December 12, 2019, the Federal Deposit Insurance Corporation (FDIC) released proposed revisions to its brokered deposit regulation that will, if finalized in their proposed form, provide long sought relief for insured...more

The Privacist - Volume 2

November will see several opportunities to discuss privacy matters in Europe and meet with The Privacist contributors within the K&L Gates’ platform, in connection with the International Association of Privacy Professionals...more

Proposed Regulations Under the California Consumer Privacy Act: Delivery and Content of Initial Notices and Disclosures

On October 10, 2019, the California attorney general issued proposed regulations under the California Consumer Privacy Act (“CCPA”). Written comments to the proposed regulations must be submitted by no later than 5:00 p.m. on...more

FinTech Forward: How to Prepare for the California Consumer Privacy Act (CCPA) - Part 1

In this miniseries, John ReVeal will discuss key issues and top of mind concerns for businesses under the California Consumer Privacy Act, which will go into effect January 1, 2020. In the first episode, John ReVeal...more

California Governor Signs Limited Amendments to the California Consumer Privacy Act

On October 11, 2019, California Governor Gavin Newsom signed five bills to amend the California Consumer Privacy Act (CCPA): AB 25, AB 874, AB 1146, AB 1355, and AB 1564. The governor’s office announced his signing of these...more

Proposed Regulations Under the California Consumer Credit Privacy Act

On October 10, 2019, the California Attorney General issued proposed regulations under the California Consumer Privacy Act (CCPA). ...more

European Community Consumer Credit Protection Laws: Similarities and Differences in the United States for Non-Mortgage Credit

Financial institutions that operate only in the United States (US) or only in the European Union (EU) might be excused for believing that they face unreasonable burdens under local consumer credit protection laws. Broadly...more

FinTech Forward: The OCC FinTech Charter

In this episode, John ReVeal discusses the background of OCC special purpose charter for FinTechs, including authority and scope. The episode also addresses the concerns and requirements for most FinTechs, including the...more

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