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Ballard Spahr LLP

Bank Policy Institute Critiques Notice of Proposed Rulemaking to Modernize AML/CFT Programs

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The Bank Policy Institute (“BPI”) has issued its comment on the Federal Functional Regulators’ (the OCC, the Board of Governors of the Federal Reserve System, the FDIC, and the National Credit Union Administration) notice of...more

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

Ballard Spahr LLP

Trade Groups Call on FDIC to Withdraw Brokered Deposit NPRM

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A group of 11 financial services associations is calling on the FDIC to withdraw its notice of proposed rulemaking intended to strengthen the prudential protections of the agency’s safety and soundness rule for brokered...more

Alston & Bird

FDIC Proposes Rule to Revise Brokered Deposit Regulations and Issues Request for Information on Deposit Data

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In a proposed rule and information request, the Federal Deposit Insurance Corporation expressed its concerns with the current brokered deposit restrictions and reporting requirements. Our Financial Services Team zeroes in on...more

Clark Hill PLC

Prudential Regulators Propose Rules Amending Anti-Money Laundering Requirements: Is Your Financial Institution Ready?

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On July 14, the Financial Crimes Enforcement Network (FinCEN) joined the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of...more

Patomak Global Partners

FDIC and OCC Focus on Resolution and Recovery Capabilities Testing

The Situation: The Federal Deposit Insurance Corporation (FDIC) has issued a final rule which substantively changes the scope and expectations for Insured Depository Institution (IDI) resolution plans (FDIC Final Resolution...more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

Mayer Brown

FinCEN Proposes Rule Reinforcing Financial Institutions’ Duty to Design and Maintain Risk-Based AML/CFT Programs

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On June 28, 2024, the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (“June 2024 NPRM”) to crystalize its long-held expectation that financial institutions use...more

Cadwalader, Wickersham & Taft LLP

FinCEN and Federal Banking Agencies Propose Amendments to Anti-Money Laundering Rules

On June 28, 2024, The U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released a notice of proposed rulemaking (the “Proposed Rule”) that would amend FinCEN’s anti-money laundering (“AML”) program rules for...more

Mayer Brown Free Writings + Perspectives

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...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

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

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On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...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

Wiley Rein LLP

Wiley Consumer Protection Download (January 8, 2024)

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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

“Open Banking” Promoted in New CFPB Rule

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​​​​​​​In October 2023, the Consumer Financial Protection Bureau (CFPB) proposed a new rule intended to encourage “open banking”. “Open banking” is a practice of sharing, with consent, consumers’ banking and financial data...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

Ballard Spahr LLP

FinCEN Proposes to Require Recordkeeping and Reporting for CVC Mixing Transactions

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On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more

Wiley Rein LLP

Wiley Consumer Protection Download (April 10, 2023)

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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

Orrick, Herrington & Sutcliffe LLP

DFPI releases second round of modifications to proposed regulations for complaints and inquiries under the CCFPL

On March 23, the California Department of Financial Protection and Innovation (DFPI or the Department) released a second round of modifications to proposed regulations for implementing and interpreting certain sections of the...more

Morgan Lewis - All Things FinReg

CFPB Proposes Additional Reporting Requirements on Non-Bank Financial Institutions

For the second time in a month, the Consumer Financial Protection Bureau (CFPB) has proposed a new rule that would require businesses to report already public information and thereby increase the burdens on, and risks to, the...more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Proposed Rule Under Section 1071 of Dodd-Frank to Collect Small Business Lending Data

On September 1, the CFPB issued a Notice of Proposed Rulemaking (NPRM) to implement Section 1071 of the Dodd-Frank Act, which amended the Equal Credit Opportunity Act (ECOA) to require financial institutions to collect and...more

Nutter McClennen & Fish LLP

Nutter Bank Report: March 2021

Federal Reserve Issues New Guidance on Managing the LIBOR Transition - The Federal Reserve has issued guidance on how examiners will assess a banking organization’s progress in preparing to transition to a replacement rate...more

Foodman CPAs & Advisors

¿Estarán las Instituciones Financieras Preparadas para la Propuesta de Reglamentación del “Travel Rule”?

El “Travel Rule” es una regla de la Ley de Secreto Bancario (“BSA”) regla [31 CFR 103.33(g)] y requiere que todas las instituciones financieras transmitan cierta información a la siguiente institución financiera, en ciertas...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

Robinson+Cole Data Privacy + Security Insider

Proposed New Breach Notification Rule for the Banking Industry

The Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) recently announced a “Notice of Proposed...more

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