News & Analysis as of

Financial Regulatory Reform NPRM

Ballard Spahr LLP

FDIC board approves NPRM that would increase recordkeeping for custodial accounts

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On September 17, 2024, the FDIC board approved a notice of proposed rulemaking that would increase recordkeeping obligations for bank deposits received from third party, non-bank companies that accept those deposits on behalf...more

Jenner & Block

Client Alert: A Second Wave: FinCEN and SEC Further Extend Investment Advisers’ AML Obligations with New CIP Requirements

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In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more

Holland & Hart LLP

CFIUS Proposed Rule Aims to Strengthen Penalty and Enforcement Measures

Holland & Hart LLP on

The US Department of the Treasury (Treasury), which chairs the Committee on Foreign Investment in the United States (CFIUS or the Committee), recently released a Notice of Proposed Rulemaking (NPRM) to augment certain CFIUS...more

Ballard Spahr LLP

The Once and Future Rule: How the CFPB’s Credit Card Late Fee Rule Compares to Regulation Z and the Previously Proposed Rule

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On March 5, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued its final credit card late fee rule (the “Final Rule”). The timing for publication of the final rule was widely perceived as coordinated with the...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - February 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Polsinelli

Part 3: Addressing and Demystifying Common Denials Surrounding the Upcoming CTA

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CTA Denial #3: “My industry’s lobbyists would never allow such a law to get passed.” Lobbyists had staved off attempts to implement the CTA, and its predecessor bills, for decades....more

Manatt, Phelps & Phillips, LLP

CFPB’s Proposes Data Rights Rule to Accelerate the Shift to “Open Banking”

On October 19, the Consumer Financial Protection Bureau (CFPB) issued its highly anticipated notice of proposed rulemaking to implement Section 1033 of the Dodd-Frank Act. The Personal Financial Data Rights Rule would require...more

Schwabe, Williamson & Wyatt PC

Corporate Transparency Act: Reporting Beneficial Ownership Starting January 2024

On January 1, 2024, the Corporate Transparency Act (the “Act” or the “CTA”) will go into effect. It is expected to impact approximately 32.6 million small and medium-sized businesses in unregulated industries in its first...more

Orrick, Herrington & Sutcliffe LLP

House Republicans question CFPB’s card late-fee proposal

On March 1, several Republican House Financial Services Committee members sent a letter to CFPB Director Rohit Chopra expressing concerns over the Bureau’s credit card late fee proposal. ...more

Bilzin Sumberg

Key Updates in the Transparency World for Private Clients

Bilzin Sumberg on

FinCEN Proposes the Second Installment to the Corporate Transparency Act - On December 15, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the "Notice") in relation to the...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Issues Proposed Rules under LIBOR Act

On July 19, the Federal Reserve issued a notice of proposed rulemaking (“NPR”) that would implement the Federal LIBOR Act. The NPR focuses primarily on identifying the particular version of SOFR that will apply to legacy...more

Cadwalader, Wickersham & Taft LLP

Federal Banking Agencies Issue Interagency Proposal to Update Community Reinvestment Act Rules

On May 5, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a notice of proposed rulemaking to...more

Foodman CPAs & Advisors

¿Cómo implementará FinCEN las Provisiones de Reportaje de Información de los Dueños Beneficiarios de la Ley de Transparencia...

FinCEN ha estado ocupada en la búsqueda de combatir la corrupción, como lo demuestra la emisión consecutiva de Avisos de Propuesta de Reglamentación (“NPRMs”). El 6/12/21, emitieron el (Proceso regulatorio para los nuevos...more

Foodman CPAs & Advisors

How will FinCEN Implement the Beneficial Ownership Information Reporting Provisions of the Corporate Transparency Act (CTA)? They...

FinCEN has been busy in the quest to fight corruption as evidenced by back-to-back issuance of Notices of Proposed Rulemaking (NPRMs).  On 12/6/21, they issued the (Regulatory Process for New Real Estate Sector Reporting...more

Burr & Forman

FinCEN Issues Proposed Beneficial Ownership Reporting Rules to the Corporate Transparency Act

Burr & Forman on

Background and Development - On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) for the Corporate Transparency Act (the “CTA”).  ...more

Hogan Lovells

New proposed rule requires banks to notify regulators within 36 hours of a cybersecurity incident

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On January 12, 2021, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) published a Notice of Proposed...more

Ballard Spahr LLP

FTC Seeks Comments On Proposed Changes To FCRA Rules

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The FTC has issued five notices of proposed rulemaking seeking comments on changes to five rules that implement the Fair Credit Reporting Act.  Comments will be due no later than 75 days after the date the NPRMs are published...more

Morgan Lewis

Volcker Rule Proposal: The Covered Funds Shoe Starts to Drop

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On January 30, the five federal financial agencies (Agencies) responsible for the administration of the Volcker Rule—the federal prohibitions on proprietary trading and private fund (covered funds) investments and sponsorship...more

Mayer Brown

Potential Volcker Rule Changes Announced

Mayer Brown on

On January 30, 2020, five federal financial regulatory agencies published the long awaited notice of proposed rulemaking (the “NPR”) to revise certain aspects of the Volcker Rule (Section 13 of the Bank Holding Company Act)...more

Ballard Spahr LLP

Response from community groups to OCC/FDIC joint CRA proposal

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While banks, community groups, and regulators all seem to agree that there is a need to reform the Community Reinvestment Act (the “CRA”), which was signed into law by Jimmy Carter back in 1977 and hasn’t received a major...more

Ballard Spahr LLP

Community groups call on regulators to issue uniform CRA

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On Monday, September 9, 2019, a group of 28 housing, consumer protection and community development organizations issued a letter to the Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency and...more

Polsinelli

The CFPB’s Long Awaited Debt Collection Rule is Certain to Shake Up the Industry

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On May 7, 2019, the Consumer Financial Protection Bureau (CFPB) issued a Notice of Proposed Rulemaking (the Proposed Rulemaking) to implement portions of the Fair Debt Collection Practices Act (FDCPA)....more

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