As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more
7/17/2024
/ Banking Regulators ,
Banks ,
Community Banks ,
Compliance ,
Coronavirus/COVID-19 ,
FDIC ,
Federal Reserve ,
FinTech ,
OCC ,
Partnerships ,
Regulatory Requirements ,
Risk Management
Agencies Issue Final Guidance on Third-Party Risk Management -
On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more
6/12/2023
/ Algorithms ,
Artificial Intelligence ,
Automation Systems ,
Banking Sector ,
Bots ,
Capital Formation ,
CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
FDIC ,
Federal Reserve ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
FinTech ,
Liquidity ,
OCC ,
Policies and Procedures ,
Private Investment Funds ,
Proposed Rules ,
Publicly-Traded Companies ,
Risk Management ,
Swap Dealers ,
Swaps ,
Third-Party Relationships ,
Third-Party Risk
Regulatory Developments -
Overdraft Protection Programs: Risk Management Practices -
On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more
5/1/2023
/ Banking Sector ,
Banks ,
Broker-Dealer ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Duty of Care ,
ECOA ,
Enforcement Actions ,
FDIC ,
Financial Services Industry ,
FSOC ,
FTC Act ,
Investment Adviser ,
New Guidance ,
OCC ,
Overdraft Fees ,
Redlining ,
Regulation BI ,
Risk Management ,
Section 5 ,
Unfair or Deceptive Trade Practices
Regulatory Developments -
Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities -
On February 23, the Federal Reserve, FDIC and OCC (the Agencies) issued a “Joint...more
3/3/2023
/ Adjudicatory Process ,
Change in Control ,
Construction Loans ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Cryptoassets ,
Disclosure Requirements ,
FDIC ,
Financial Regulatory Agencies ,
Financial Stability Board ,
Liquidity ,
OCC ,
Risk Assessment ,
Risk Management
Regulatory Developments -
Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial Risks -
On December 2, the Federal Reserve announced that it...more
12/12/2022
/ Broker-Dealer ,
Climate Change ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Federal Reserve ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Initial Public Offering (IPO) ,
Investment Adviser ,
Military Service Members ,
Nasdaq ,
NYSE ,
OCC ,
Payment Systems ,
Preemption ,
Proposed Regulation ,
Public Comment ,
Pump and Dump ,
Regulation S-ID ,
Risk Management ,
Servicemembers Civil Relief Act (SCRA) ,
Truth in Lending Act (TILA)
Regulatory Developments -
Federal Reserve Seeks Feedback on Proposed Updates to FMUs Risk Management Requirements -
On September 23, the Federal Reserve invited comment on proposed updates to operational risk...more
10/3/2022
/ 10b5-1 Plans ,
Broker-Dealer ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Enforcement Actions ,
Federal Reserve ,
Financial Institutions ,
Financial Market Utilities ,
Forbearance Agreements ,
Investment Advisers Act of 1940 ,
Marketing ,
Mortgages ,
Refinancing ,
Risk Assessment ,
Risk Management ,
Risk Mitigation ,
Securities and Exchange Commission (SEC)
On July 29, the FDIC issued a Fact Sheet and Advisory (collectively, the Published Documents) regarding FDIC deposit insurance and crypto assets. The Published Documents emphasize that FDIC deposit insurance does not apply...more
8/5/2022
/ Banking Sector ,
Broker-Dealer ,
Business Development Companies ,
Cryptoassets ,
Department of Labor (DOL) ,
Deposit Insurance ,
Dodd-Frank ,
Employee Retirement Income Security Act (ERISA) ,
FDIC ,
Metaverse ,
Minorities ,
New Guidance ,
NPRM ,
QPAM ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act
In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more
3/18/2022
/ Abusive Acts ,
Agricultural Sector ,
Annual Reports ,
Banking Sector ,
Biden Administration ,
Blockchain ,
Broker-Dealer ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Cyber Incident Reporting ,
Cybersecurity ,
Digital Assets ,
Disclosure Requirements ,
Division of Trading and Markets ,
Examination Procedures ,
Executive Orders ,
Exemptions ,
FDIC ,
Final Rules ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
Insured Depository Institutions ,
Investors ,
Manufactured Housing ,
OCC ,
Proposed Rules ,
Publicly-Traded Companies ,
Reporting Requirements ,
Risk Management ,
Risk Mitigation ,
Rural Areas ,
Securities and Exchange Commission (SEC) ,
Stress Tests ,
Suspicious Activity Reports (SARs) ,
Time Extensions ,
UDAAP ,
Unfair or Deceptive Trade Practices
In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more
3/14/2022
/ Banking Sector ,
Belarus Sanctions ,
Beneficial Owner ,
Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Digital Assets ,
Economic Sanctions ,
Executive Orders ,
FATF ,
FDIC ,
Financial Action Task Force ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investors ,
Money Laundering ,
OCC ,
Risk Assessment ,
Risk Management ,
Russia ,
Shell Corporations ,
Terrorist Financing ,
U.S. Treasury ,
Virtual Currency
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more
2/11/2022
/ Appraisal ,
Banking Sector ,
Beneficial Owner ,
Borrowers ,
Comment Period ,
Community Development ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Transparency Act ,
Cyber Attacks ,
Cyber Threats ,
Cybersecurity ,
Dodd-Frank ,
Fair Lending ,
FDIC ,
Federal Reserve ,
Federal Savings Associations ,
Financial Services Industry ,
FinCEN ,
FinTech ,
Investment Adviser ,
Investment Companies ,
Lenders ,
New Rules ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Policies and Procedures ,
Private Funds ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Reporting Requirements ,
Risk Management ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
State Savings Associations ,
Valid When Made Doctrine
In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more
1/7/2022
/ Antitrust Division ,
Banking Sector ,
Banks ,
Beneficial Owner ,
Best Practices ,
Board of Governors ,
Broker-Dealer ,
Climate Change ,
Comment Period ,
Community Banks ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Depository Institutions ,
Disclosure Requirements ,
Division of Investment Management ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Foreign Corporations ,
Form CRS ,
Mergers ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Ownership Requirements ,
PCAOB ,
Proposed Rules ,
Public Comment ,
Publicly-Traded Companies ,
Registered Investment Advisors ,
Reporting Requirements ,
Repurchases ,
Retail Investors ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more
12/17/2021
/ 10b5-1 Plans ,
AML/CFT ,
Bank Secrecy Act ,
Banking Sector ,
Chief Compliance Officers ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Electronic Fund Transfer Act ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Insider Trading ,
Investment Company Act of 1940 ,
Investment Funds ,
Money Market Funds ,
OCC ,
Policies and Procedures ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Regulation E ,
Regulatory Agenda ,
Reporting Requirements ,
Request For Information ,
Risk Management ,
Rule 2a-7 ,
Rulemaking Process ,
SBS Entities ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Security-Based Swaps ,
Stock Repurchases ,
Swap Dealers ,
Trading Plans
In this Issue. The U.S. Securities and Exchange Commission’s (SEC) Division of Examinations recently published a risk alert spotlighting observations from its “RIC Initiatives”; the Federal Financial Institutions Examination...more
11/8/2021
/ Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Examination Procedures ,
FFIEC ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Services Industry ,
Guidance Documents ,
Lenders ,
OCC ,
OTCBB ,
Registered Investment Companies (RICs) ,
Regulation Z ,
Risk Alert ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Truth in Lending Act (TILA)
In This Issue. The Consumer Financial Protection Bureau (CFPB) withdrew its proposal to delay the Debt Collection Final Rules; the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance...more
9/17/2021
/ Banking Sector ,
Banks ,
Broker-Dealer ,
Comment Period ,
Community Banks ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Debt Collectors ,
Digital Platforms ,
Due Diligence ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Services Industry ,
FinTech ,
FRB ,
Investment Adviser ,
Investment Companies ,
Investment Company Act of 1940 ,
OCC ,
Proposed Rules ,
Public Comment ,
Regulation F ,
Retail Investors ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Third-Party Risk
In This Issue. The Office of the Comptroller of the Currency (OCC) announced that it will reconsider its controversial June 2020 final rule revising its Community Reinvestment Act (CRA) rules, and published its Semiannual...more
5/21/2021
/ Artificial Intelligence ,
Banking Sector ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Depository Institutions ,
Digital Assets ,
FDIC ,
Federal Savings Associations ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
OCC ,
Public Comment ,
Request For Information ,
Risk Management ,
TILA-RESPA Integrated Disclosure Rule (TRID)
In This Issue. The U.S. Securities and Exchange Commission (SEC) Division of Examinations issued a Risk Alert raising concerns about misleading Environmental, Social, and Governance (ESG) disclosures by investment firms; the...more
4/20/2021
/ Advertising ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Comment Period ,
Environmental Social & Governance (ESG) ,
Fannie Mae ,
FDIC ,
Federal Reserve ,
Freddie Mac ,
Notice of Proposed Rulemaking (NOPR) ,
Public Comment ,
Reporting Requirements ,
Risk Alert ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Supervisory Guidance
In the News. The Securities and Exchange Commission (SEC) adopted broad exempt offering reforms; the Department of Labor (DOL) finalized a rule, with significant revisions from the original proposal, on ESG investments; the...more
11/5/2020
/ Banking Sector ,
Capital Formation ,
Climate Change ,
Confidential Information ,
Consent Order ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Department of Financial Services ,
Department of Labor (DOL) ,
Derivatives ,
Disclosure Requirements ,
Employee Retirement Income Security Act (ERISA) ,
Environmental Social & Governance (ESG) ,
FDCPA ,
FDIC ,
Federal Reserve ,
Fiduciary ,
Fiduciary Duty ,
Final Rules ,
Financial Institutions ,
Financial Records ,
Financial Regulatory Agencies ,
Financial Regulatory Reform ,
Financial Services Industry ,
Initial Public Offering (IPO) ,
Investment Companies ,
Investment Funds ,
Investment Opportunities ,
Investors ,
Lenders ,
Main Street Lending Programs ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Offerings ,
Proposed Rules ,
Public Comment ,
Registered Funds ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Small Business ,
Small Business Loans ,
UDAAP
SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more
10/8/2020
/ Banking Regulators ,
Banking Sector ,
Borrowers ,
Capital Requirements ,
Change of Ownership ,
Class Action ,
Community Reinvestment Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Current Expected Credit Losses (CECL) ,
Dividends ,
Enforcement Actions ,
Federal Reserve ,
Final Rules ,
Financial Instruments ,
Financial Services Industry ,
Incentive Awards ,
Investment Adviser ,
Investment Companies ,
Investors ,
Mergers ,
New Guidance ,
New Rules ,
NYSE ,
OCC ,
Paycheck Protection Program (PPP) ,
Public Comment ,
Relief Measures ,
Risk Management ,
SBA ,
Securities and Exchange Commission (SEC) ,
Shareholder Approval ,
Shareholders ,
Small Banks ,
Small Business ,
Stock Repurchases ,
Stress Tests ,
Supervision ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Trust Funds ,
Truth in Lending Act (TILA) ,
Unregistered Securities
In This Issue. The Securities and Exchange Commission (SEC) adopted amendments to its exemptive applications procedures under the Investment Company Act of 1940, as amended (the 1940 Act) and proposed to amend Form 13F to...more
7/16/2020
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Cyber Attacks ,
Cybersecurity ,
FDIC ,
Federal Reserve ,
FFIEC ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Form 13F ,
Investment Company Act of 1940 ,
Investment Management ,
Joint Statements ,
Libor ,
Mortgage Escrow Account ,
New Guidance ,
OCC ,
OCIE ,
Paycheck Protection Program (PPP) ,
Phishing Scams ,
Popular ,
Proposed Rules ,
Ransomware ,
Reporting Requirements ,
Risk Alert ,
Risk Management ,
Rulemaking Process ,
SBA ,
Securities and Exchange Commission (SEC) ,
Small Dollar Lenders
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve) expanded access to its Paycheck Protection Program Liquidity Facility (PPPLF) to non-bank lenders and expanded the collateral eligible to...more
5/7/2020
/ Banking Regulators ,
Banking Sector ,
Borrowers ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Enforcement Actions ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Forbearance Agreements ,
Foreclosure ,
Lenders ,
Liquidity Coverage Ratio ,
Loan Forgiveness ,
Main Street Lending Programs ,
Money Market Mutual Fund Liquidity Facility (MMLF) ,
Mortgage Lenders ,
Mortgages ,
Nasdaq ,
New Guidance ,
Non-Bank Lenders ,
Paycheck Protection Program (PPP) ,
Paycheck Protection Program Lending Facility (PPPL Facility) ,
Price Gouging ,
Risk Management ,
SBA ,
Securities and Exchange Commission (SEC) ,
Shareholder Approval