As we have previously noted, we expect that the second Trump Administration will be significantly more favorable to crypto than the Biden Administration, especially with the recent appointment of David Sacks as the...more
Recently, the Industrial and Commercial Bank of China Ltd. (“ICBC”) entered into two consent orders. The first consent order is with the New York State Department of Financial Services (the “NYDFS”) for alleged deficiencies...more
On January 19, the Federal Reserve Board (FRB) and New York Department of Financial Services (NYDFS) each issued orders settling an action against a large global bank for alleged BSA/AML violations and other compliance...more
On April 25, the Consumer Financial Protection Bureau (CFPB or Bureau) announced that it would begin invoking a provision in Dodd-Frank, previously used only infrequently, to conduct supervisory examinations over a greater...more
The European Securities and Markets Authority has published its final Market Abuse Guidelines on the disclosure of inside information and interactions with national prudential regulators under the EU Market Abuse Regulation....more
CSI: Confidential Supervisory Information is not a show many banks would enjoy watching, but it’s one of three areas our Financial Services & Products Group notes banks should keep in mind if they become the subject of...more
In This Issue. The Securities and Exchange Commission (SEC) finalized amendments to its proxy solicitation rules that will modify the practices of proxy advisory firms, providing them with greater transparency and...more
The New York State Department of Financial Services (“DFS”) is proposing a new regulation that would allow banks to share confidential supervisory information with their attorneys or an independent auditor without gaining...more
Last week, the New York Department of Financial Services (“NYDFS”) announced a proposed new regulation that provides greater flexibility for entities licensed, chartered, authorized, registered, or supervised by the NYDFS to...more
Public companies that have previously obtained a confidential treatment order from the Staff of the Securities and Exchange Commission for a material contract filed as an exhibit under the periodic reporting requirements of...more
Join this free educational event—brought to you by the NAVEX Global Ethics & Compliance Virtual Conference—for 2.5 hours of quality learning. Become an expert investigator in 1 day! In this Master Class, you will learn...more
A serious regulatory issue can derail a bank merger or acquisition. Sometimes a bank will begin a transaction with a known, pre-existing regulatory issue, and other times an unanticipated regulatory issue develops during the...more
The CFPB issued a proposed rule which significantly affects third-party access to information obtained by the Bureau. In addition to public requests under the Freedom of Information Act, the Privacy Act of 1974 and in legal...more
Without an announcement, the CFPB has proposed a rule that would expand its discretion to share confidential supervisory information (CSI) with state attorneys general and other agencies that do not have supervisory authority...more
The pursuit of examinations and enforcement actions by the Consumer Financial Protection Bureau (CFPB) has created new challenges for entities that provide consumer financial products and services. Given the CFPB’s broad...more
The European Banking Authority has published a recommendation setting out its opinion on the confidentiality regime of several non-EU supervisory authorities to facilitate their participation in supervisory colleges...more
On January 27, 2015, the Consumer Financial Protection Bureau (“CFPB”) issued a compliance bulletin reminding supervised financial institutions (including large depository institutions, credit unions and their affiliates,...more
Is your financial institution or company subject to the Consumer Financial Protection Bureau’s (CFPB) supervision? If so, take note of a recent bulletin warning supervised entities – both banks and non-banks – about the...more
On January 27, 2015, the Consumer Financial Protection Bureau (“CFPB”) issued a Compliance Bulletin 2015-1 (the “Bulletin”) reminding supervised financial institutions about regulatory requirements surrounding Confidential...more
The CFPB issued a compliance bulletin setting forth its views that, with limited exceptions, persons in possession of confidential information, including confidential supervisory information, or CSI, may not disclose such...more