News & Analysis as of

Consent Order Risk Management

Goodwin

Supervisory Experience and Enforcement Actions Continue to Drive Supervisory Priorities and Policy Development

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This article identifies themes we have observed in recent public formal enforcement actions issued to institutions by the US federal bank regulatory agencies (Agencies) — the Board of Governors of the Federal Reserve System...more

Ballard Spahr LLP

Recent FDIC Consent Orders Reflect Ongoing Scrutiny of Bank Relationships with Fintechs

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In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness concerns relating...more

Troutman Pepper

FDIC Announces Two More Consent Orders Containing Third-Party Risk Management and Fintech Partnership Orders

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On March 29, the Federal Deposit Insurance Corporation (FDIC) announced two more consent orders containing provisions relating to banks’ third-party risk management programs with respect to banking as a service (BaaS)...more

Ballard Spahr LLP

Congressional Representatives Express Concern Regarding FDIC’s Regulation of FinTech Firms and Financial Innovation

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On February 2, 2024, three Republican members of the House Financial Services Committee sent a letter to Federal Deposit Insurance Corporation (“FDIC”) Chair Martin Gruenberg expressing concern regarding what the congressmen...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - December 2024

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Adams and Reese LLP

FDIC Sends Clear Message in Recent Enforcement Action: BaaS/Fintech Partnerships are a High-Risk Compliance Area

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Last month, the Federal Deposit Insurance Corporation (“FDIC”) took action against a bank for alleged unsafe or unsound banking practices. This, in and of itself, is not usual or newsworthy. What is unusual and newsworthy,...more

Jackson Lewis P.C.

NYSDFS Fines Lender and Mortgage Servicer $4.25M for Cybersecurity Failures Including Vendor Management

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Yesterday, New York’s Department of Financial Services (“DFS”) announced another enforcement action under the state’s Cybersecurity Requirements for Financial Services Companies, 23 N.Y.C.R.R. Part 500 (“Reg 500”). According...more

ArentFox Schiff

Managing Third-Party Risk: Recent FCPA Action Reflects Government’s Continued Focus on Intermediaries

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Amec Foster Wheeler Energy Limited (the Company), a subsidiary of John Wood Group plc (Wood), a United Kingdom-based global engineering company, agreed to pay more than $41 million in penalties and disgorgement for alleged...more

Wiley Rein LLP

Wiley Consumer Protection Download (June 7, 2021)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Goodwin

SEC Adopts Broad Exempt Offering Reforms

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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

Balch & Bingham LLP

OCC Issues $400 Million Civil Penalty in Consent Order with Citibank Over Risk and Data Governance

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On October 7, 2020, The Office of the Comptroller of the Currency (“OCC”) announced that it had assessed a $400 million civil penalty against Citibank, N.A. regarding alleged deficiencies in it enterprise-wide risk management...more

ArentFox Schiff

Investigations Newsletter: Investment Bank Fined $400 Million For Failing to Remediate Deficiencies in its Risk Management Systems

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Investment Bank Fined $400 Million For Failing to Remediate Deficiencies in its Risk Management Systems - On October 7, the Federal Reserve Board and Office of the Comptroller of the Currency issued a consent order...more

Goodwin

SEC Charges Trust Company With Operating Unregistered Investment Companies

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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

Sunstein LLP

Twenty Years Under the Microscope: A Small Business, a Data Breach and the FTC

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James Grago has a nice business going. He runs a website called ClixSense.com that permits users to earn money by completing surveys and watching advertisements. Revenues grew from $6.7 million in 2015 to $9.1 million in...more

Fenwick & West LLP

FTC Toughening Stance on Data Security – Five Key Takeaways from Recent Consent Orders

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The Federal Trade Commission is putting more teeth into the multiyear compliance obligations of consent orders it enters into with companies to settle enforcement actions related to data breaches. The FTC recently issued a...more

The Volkov Law Group

Federal Reserve Hits Wells Fargo with Unprecedented Enforcement Action (Part I of II)

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In an extraordinary action, with significant ramifications for the financial industry, the Federal Reserve recently announced a series of enforcement actions against Wells Fargo....more

Goodwin

Financial Services Weekly News - June 2017 #2

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Editor's Note - Financial Regulatory Reform Picks Up Speed. The Trump administration, which views burdensome and costly regulation as a significant impediment to lending and economic growth, has consistently maintained...more

Morrison & Foerster LLP

RESPA Two-Step: CFPB Shows Continued Expansive Interpretation of Section 8

On January 31, 2017, the Consumer Financial Protection Bureau (“CFPB”) announced a Consent Order (“Order”) with Prospect Mortgage LLC and certain of its affiliates (“Lender”). The CFPB alleged in the Order widespread...more

Morrison & Foerster LLP

Financial Services Report, Winter 2016

EDITOR’S NOTE - Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more

Cozen O'Connor

Update on Significant DOT, FAA and Other Federal Agencies’ Aviation-Related Regulatory Actions - October 2015

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This edition of the Cozen O’Connor Aviation Regulatory Update reports on Congress’s six-month extension of FAA’s reauthorization; new U.S. Bilateral Aviation Safety Agreements with the European Union and Canada; the FAA’s...more

Goodwin

Fair Servicing: Regulators Watch for Discrimination by Servicers

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Federal regulators delivered that message in October 2013, reminding loan servicers that they are subject to fair lending liability and must manage their fair lending risks. The regulators’ message concerning “fair servicing”...more

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