On May 19, FinCEN and BIS issued an alert urging financial institutions to watch for attempts to evade export controls imposed on Russia. The alert focuses on ongoing federal initiatives to limit Russian access to technology...more
5/26/2023
/ Bureau of Industry and Security (BIS) ,
CFTC ,
Consumer Financial Protection Bureau (CFPB) ,
Derivatives Clearing Organizations ,
Economic Sanctions ,
Evasion ,
Export Controls ,
Financial Institutions ,
FinCEN ,
FinTech ,
Freddie Mac ,
Interest Rates ,
Registration Requirement ,
Russia ,
Safeguards Rule ,
Securities and Exchange Commission (SEC) ,
UDAAP
Regulatory Developments -
FinCEN Issues Initial Beneficial Ownership Information Reporting Guidance -
On March 24, FinCEN published guidance materials for the new beneficial ownership reporting requirements taking...more
4/17/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Commercial Loans ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Transparency Act ,
Credit Cards ,
Financial Institutions ,
FinCEN ,
Preemption ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Truth in Lending Act (TILA)
Regulatory Developments -
FinCEN Proposes Form of Report to Collect Beneficial Ownership Information and Application to Obtain FinCEN Identifiers -
On January 17, FinCEN proposed a form of report to collect beneficial...more
1/27/2023
/ Beneficial Owner ,
Broker-Dealer ,
Civil Monetary Penalty ,
Climate Change ,
Consumer Financial Protection Bureau (CFPB) ,
Examination Priorities ,
Federal Reserve ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
FinCEN ,
Mortgage Servicers ,
New Guidance ,
Reporting Requirements ,
Risk Assessment ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Transfer on Death Deed (TOD)
Regulatory Developments -
FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards -
On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more
1/18/2023
/ 10b5-1 Plans ,
Anti-Money Laundering ,
Beneficial Owner ,
Community Reinvestment Act ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Corporate Transparency Act ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
FinCEN ,
Interest Rates ,
Libor ,
New Guidance ,
Nonbank Firms ,
NPRM ,
Regulation O ,
Regulation Z ,
Relief Measures ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Small Banks ,
Threshold Requirements ,
Time Extensions
In This Issue. The Financial Crimes Enforcement Network (FinCEN) is urging financial institutions to focus their efforts on detecting the proceeds of foreign public corruption; the Financial Industry Regulatory Authority...more
4/22/2022
/ Annual Reports ,
Bribery ,
Climate Change ,
Corruption ,
Embezzlement ,
Environmental Social & Governance (ESG) ,
ETFs ,
Extortion ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Statements ,
FinCEN ,
Greenhouse Gas Emissions ,
Investors ,
Misappropriation ,
Money Laundering ,
Proposed Amendments ,
Proposed Rules ,
Public Corruption ,
Publicly-Traded Companies ,
Registration Statement ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
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 Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more
2/18/2022
/ Augmented Reality ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
Derivatives ,
FDIC ,
Federal Reserve ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment Firms ,
Investors ,
OCC ,
OMB ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Reporting Requirements ,
Rulemaking Process ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Stress Tests ,
Virtual Reality ,
Whistleblower Protection Policies ,
Whistleblowers
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 Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more
1/28/2022
/ Borrowers ,
Broker-Dealer ,
Civil Monetary Penalty ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Cross-Border ,
Deposit Insurance ,
Disclosure Requirements ,
Division of Investment Management ,
European Securities and Markets Authority (ESMA) ,
Examination Procedures ,
FDIC ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Fund Distribution ,
Inflation Adjustments ,
Investors ,
Irrevocable Trusts ,
Lenders ,
Marketing ,
Mortgage Servicers ,
New Rules ,
Notice of Proposed Rulemaking (NOPR) ,
Pilot Programs ,
Proposed Rules ,
Public Comment ,
Reporting Requirements ,
Revocable Trusts ,
Securities and Exchange Commission (SEC) ,
Student Loans ,
Suspicious Activity Reports (SARs)
In This Issue. The Federal Deposit Insurance Corporation (FDIC), the FDIC Tech Lab (FDITECH) and the Financial Crimes Enforcement Network (FinCEN) launched a digital identity Tech Sprint; FinCEN published a 60-day notice to...more
1/17/2022
/ (SEC) Rule 17a-4 ,
Bank Secrecy Act ,
Banking Sector ,
Broker-Dealer ,
Comment Period ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
Financial Transactions ,
FinCEN ,
OMB ,
Proposed Amendments ,
Public Comment ,
Recordkeeping Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Security-Based Swaps
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 Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more
1/7/2021
/ Advisory Opinions ,
Appeals ,
Banking Sector ,
Broker-Dealer ,
Cash Solicitation Rule ,
Community Reinvestment Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Interim Final Rules (IFR) ,
Interpretive Letters ,
Investment Adviser ,
Lenders ,
OCC ,
OCIE ,
Paycheck Protection Program (PPP) ,
Popular ,
Preemption ,
Proposed Rules ,
Recordkeeping Requirements ,
Regulation Z ,
Relief Measures ,
Reporting Requirements ,
Risk Alert ,
Safe Harbors ,
SAR ,
SEC Advertising Rule ,
Securities and Exchange Commission (SEC) ,
Securities Litigation ,
Securities Violations ,
Special Purpose Entities
In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more
10/29/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Amended Rules ,
Bank Secrecy Act ,
Banking Sector ,
CFTC ,
Community Development Financial Institution (CDFI) ,
Comptroller ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Depository Institutions ,
Derivatives ,
FDCPA ,
FDIC ,
Federal Reserve ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Records ,
Financial Services Industry ,
FinCEN ,
FinTech ,
Forbearance Agreements ,
Insured Depository Institutions ,
Inter-Bank Offered Rates (IBORs) ,
Investors ,
ISDA ,
Military Service Members ,
Mortgages ,
OCC ,
Private Investment Funds ,
Proposed Rules ,
Proxy Statements ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC) ,
Shareholder Proposals ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Travel Rule ,
True Lender ,
Truth in Lending Act (TILA)
In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more
9/24/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Bank Holding Company Act ,
Bank Secrecy Act ,
Banking Sector ,
Blockchain ,
Borrowers ,
CD&I ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Products ,
Coronavirus/COVID-19 ,
Cryptocurrency ,
CSBS ,
Cyber Attacks ,
Debt Collection ,
Debtors ,
Depository Institutions ,
Digital Assets ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Governor Newsom ,
Hackers ,
Interpretive Letters ,
Lenders ,
Main Street Lending Programs ,
Money Transmitter ,
New Legislation ,
OCC ,
OCIE ,
Payment Processors ,
Proposed Rules ,
Public Comment ,
Regulation S-K ,
Risk Alert ,
Securities and Exchange Commission (SEC) ,
Stablecoins ,
Stress Tests ,
Underwriting
In the News. The Securities and Exchange Commission (SEC) adopted final rules to update and expand the statistical disclosures that bank and savings and loan registrants must provide to investors for the first time in 30...more
9/17/2020
/ Accredited Investors ,
Amended Rules ,
Anti-Money Laundering ,
Banking Sector ,
Banks ,
Brokers ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Crowdfunding ,
Data Collection ,
Deposit Insurance ,
Disclosure Requirements ,
Disparate Impact ,
Dodd-Frank ,
Extensions ,
Fair Credit Reporting Act (FCRA) ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Filing Fees ,
Final Rules ,
Financial Reporting ,
Financial Services Industry ,
FinCEN ,
Flood Insurance ,
HUD ,
Interim Final Rules (IFR) ,
Investors ,
Leverage Ratio ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Public Comment ,
Qualified Institutional Buyers ,
Relief Measures ,
Savings and Loan Companies ,
Section 1071 ,
Securities and Exchange Commission (SEC) ,
Small Business ,
Temporary Regulations ,
Time Extensions
In This Issue. The U.S. Supreme Court struck down the single director leadership structure of the Consumer Financial Protection Bureau (CFPB) in a ruling that could have far-reaching implications for the CFPB and other...more
7/6/2020
/ Banking Sector ,
Broker-Dealer ,
CFTC ,
Conflicts of Interest ,
Constitutional Challenges ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Dodd-Frank ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Eviction ,
FDIC ,
Federal Reserve ,
Fees ,
FHFA ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Flood Insurance ,
Forbearance Agreements ,
Hemp Related Businesses ,
Investment Adviser ,
Investment Management ,
MNPI ,
OCC ,
OCIE ,
Paycheck Protection Program (PPP) ,
Popular ,
Private Equity Funds ,
Proposed Regulation ,
Removal For-Cause ,
Reversal ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Seila Law LLC v Consumer Financial Protection Bureau ,
Separation of Powers ,
Severability Doctrine ,
Single Director ,
Tenants
In This Issue. The Office of the Comptroller of the Currency (OCC) released its annual supervision operating plan outlining its bank supervision priorities, issued an updated Truth in Lending Act booklet, and provided...more
10/4/2018
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Corrective Actions ,
Cybersecurity ,
Financial Services Industry ,
FinCEN ,
Form 10-Q ,
Loans ,
OCC ,
Payday Loans ,
Securities and Exchange Commission (SEC) ,
Truth in Lending Act (TILA)
Editor's Note -
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve), the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (together, the Federal...more
Editor's Note -
In This Issue. The Securities and Exchange Commission (SEC) issued a no-action letter that closes the gap in investor protection created by the SEC’s approval of FINRA Rule 2165; the SEC’s Investment...more
Regulatory Developments -
FinCEN Provides 90-Day Exceptive Relief From Beneficial Ownership Requirements for Certain Products and Services With Automatic Rollovers or Renewals -
On May 16, the Financial Crimes...more
5/24/2018
/ Anti-Money Laundering ,
Consumer Financial Protection Bureau (CFPB) ,
Federal Trade Commission (FTC) ,
Financial Industry Regulatory Authority (FINRA) ,
FinCEN ,
OCC ,
RESPA ,
Securities and Exchange Commission (SEC) ,
TCPA ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Truth in Lending Act (TILA)
Editor's Note -
In This Issue. The Consumer Financial Protection Bureau (CFPB) published its Spring 2018 rulemaking agenda; the U.S. Department of Housing and Urban Development (HUD) announced that it will seek public...more
Editor's Note -
Treasury Issues Recommendations to Modernize the Community Reinvestment Act. On April 3, the U.S. Department of the Treasury released a report containing its recommendations for modernizing the Community...more
4/5/2018
/ Appeals ,
Arbitration ,
Commercial Real Estate Market ,
Consumer Financial Protection Bureau (CFPB) ,
FDIC ,
Federal Arbitration Act ,
Federal Reserve ,
FHFA ,
Financial Services Industry ,
FinCEN ,
Libor ,
Mortgages ,
OCC ,
SCOTUS ,
Small Entity Compliance Guide