Daily Financial Regulation Update -- Tuesday, February 27, 2024

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Federal Agencies

Federal Reserve Board

OIG Report: Results of Security Control Testing of the Board's Projection Collection System

February 26, 2024

The Office of Inspector General of the Federal Reserve Board published a report entitled, "Results of Security Control Testing of the Board's Projection Collection System."

Office of the Comptroller of the Currency

Notice of Proposed Rulemaking to Amend Freedom of Information Act Regulations

February 26, 2024

The Office of the Comptroller of the Currency (OCC) published a notice of proposed rulemaking (NPR) that would amend its Freedom of Information Act (FOIA) regulations codified at 12 CFR 4 to include procedures on expedited processing of FOIA requests, provide for appeals of denials of expedited processing and denials of fee waiver requests, remove the "competitive harm" standard for information provided to the government on an involuntary basis, and make a conforming amendment pertaining to FOIA fee waivers. The deadline for comments on the proposed rule is April 22, 2024.

FINRA

FINRA Adopts Amendments to Conform its Rules to the T+1 Settlement Cycle

February 26, 2024

FINRA has adopted amendments to conform its rules to the Securities and Exchange Commission's (SEC) amendments to Rule 15c6-1 and adoption of Rule 15c6-2 under the Securities Exchange Act of 1934 to shorten the standard settlement cycle for most broker-dealer transactions from two business days after the trade date (T+2) to one business day after the trade date (T+1).

FINRA Adopts Amendments to Improve the Accessibility of Order Routing Disclosures for NMS Securities

February 26, 2024

FINRA is adopting new Rule 6151 (Disclosure of Order Routing Information for NMS Securities) to require members to submit to FINRA for centralized publication the order routing reports required under the Securities and Exchange Commission's (SEC) Rule 606(a) (Rule 606(a) Reports).

U.S. Small Business Administration

SBA Announces Statutory Increases for Surety Bond Guarantee Program

February 26, 2024

The U.S. Small Business Administration announced that for the first time since 2013, the SBA is increasing the statutory contract limits for the Surety Bond Guarantee Program.

Federal Housing Finance Agency

Prepayment Monitoring Report Fourth Quarter 2023

February 26, 2024

The Federal Housing Finance Agency published the Prepayment Monitoring Report for the Fourth Quarter 2023.

Bank Policy Institute

Blog: 10 Pitfalls to Avoid When Designing Any Additional Liquidity Requirements

February 26, 2024

The Bank Policy Institute published a blog post entitled, "10 Pitfalls to Avoid When Designing Any Additional Liquidity Requirements."

Administration Changes

Vacancies

Office of the Comptroller of the Currency

  • Comptroller – Vacant (Michael Hsu serves as Acting Comptroller)

Appointments/Confirmation Hearings

U.S. Department of the Treasury – Janet Yellen (effective January 26, 2021)

Federal Reserve Board – Jerome H. Powell (effective May 23, 2022)

  • Vice Chair Phillip N Jefferson (sworn in September 13, 2023)
  • Vice Chair for Supervision Michael Barr (sworn in July 19, 2022)
  • Governor Michelle W. Bowman (sworn in November 26, 2018)
  • Governor Christopher J. Waller (sworn in December 18, 2020)
  • Governor Lisa D. Cook (sworn in September 13, 2022)
  • Governor Adriana D. Kugler (sworn in September 13, 2023)

Federal Reserve Bank of New York – John C. Williams (effective June 18, 2018)

Federal Reserve Bank of Boston – Susan M. Collins (effective July 1, 2022)

Federal Deposit Insurance Corporation – Martin Gruenberg (effective January 5, 2023)

  • Vice Chairman Travis Hill (sworn in January 5, 2023)
  • Director Jonathan McKernan (sworn in January 5, 2023)
  • Director Michael Hsu (Acting Comptroller of the Currency)
  • Director Rohit Chopra (Director of Consumer Financial Protection Bureau)

Office of the Comptroller of the Currency – Michael Hsu (acting Comptroller, effective May 10, 2021)

Securities and Exchange Commission – Gary Gensler (effective April 17, 2021)

Commodity Futures Trading Commission – Rostin Behnam (effective December 17, 2021)

Consumer Financial Protection Bureau – Rohit Chopra (effective October 12, 2021)

National Credit Union Administration – Todd M. Harper (effective January 20, 2021)

Small Business Administration – Isabella Casillas Guzman (effective March 16, 2021)

U.S. Department of Housing and Urban Development – Marcia Fudge (effective March 10, 2021)

Federal Housing Finance Agency – Sandra L. Thompson (effective June 22, 2022)

U.S. Department of Education – Dr. Miguel Cardona (effective March 2, 2021)

Financial Crimes Enforcement Network – Andrea Gacki (effective July 13, 2023)

PH Client Alerts

Click here to read more from our Coronavirus series.

Legislation/Legislative Updates

Click here to view the full text of the Coronavirus Aid, Relief and Economic Security Act (the "CARES Act"), Enacted March 27, 2020.

Click here to view the full text of the Paycheck Protection Program Increase Act of 2020, Enacted April 24, 2020.

Click here to view the full text of the Paycheck Protection Program Flexibility Act of 2020, Enacted June 5, 2020.

Click here to view the full text of the Consolidated Appropriations Act, 2021, Enacted December 27, 2020.

Click here to view the full text of the American Rescue Plan of 2021, Enacted March 11, 2021.

Click here to view the full text of the PPP Extension Act of 2021, Enacted March 30, 2021.

Click here to view a running list of proposed legislation from the Senate Committee on Banking, Housing, and Urban Affairs, Senate Committee on Small Business and Entrepreneurship, House Committee on Financial Services, and House Committee on Small Business.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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