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The Volkov Law Group

TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements  (Part III of IV)

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TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 2 – When Profits Trump Compliance: A Recipe for Corporate Disaster

We continue our exploration of the resolution of the AML/BSA enforcement action involving TD Bank US (the Bank), which is wholly owned by TD Bank Group, a publicly traded (NYSE: TD) international banking and financial...more

The Volkov Law Group

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

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In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 1-Money Laundering and the China Syndrome

Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more

Ballard Spahr LLP

Federal Agencies Finalize Reconsideration of Value Guidance

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A group of federal agencies have finalized reconsideration of value (ROV) guidance for residential real estate valuations. The agencies are the Comptroller of the Currency (OCC), Consumer Financial Protection Bureau (CFPB),...more

Cadwalader, Wickersham & Taft LLP

Federal Banking Agencies Finalize Community Reinvestment Act Rules

On Tuesday, 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 final rule to amend and update...more

Ballard Spahr LLP

Federal Reserve Board and FDIC expected to approve final Community Reinvestment Act rules at Oct. 24 meetings

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At its open Board meeting scheduled for October 24, 2023, the Federal Reserve Board is expected to approve its final rule amending its current regulation implementing the Community Reinvestment Act....more

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Capital Endgame Proposal

On Monday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the American Bankers Association Annual Convention entitled Capital Supports Lending regarding the Basel III...more

Cadwalader, Wickersham & Taft LLP

Industry Trades Really Don’t Like the Basel III Endgame Proposal

As we covered previously, on July 27, 2023, the U.S. prudential bank regulators (the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”)...more

Cadwalader, Wickersham & Taft LLP

The Three Federal Banking Agencies Propose Long-Term Debt Requirement for All Large Banking Organizations

The Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a proposed rule (the “LTD NPR”) to require large banks...more

Ballard Spahr LLP

Federal Reserve Board issues letters on program to supervise novel banking activities

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Earlier this month, the Federal Reserve Board (FRB) released two supervision and regulation letters regarding the agency’s program to supervise “novel” banking activities....more

Cadwalader, Wickersham & Taft LLP

Capital Idea? Risk-Based Capital, Capital Relief Trades and the Proposed Basel III Endgame Capital Rules

On July 27, 2023, the U.S. federal prudential bank regulators (the Federal Deposit Insurance Corporation, the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency) proposed new capital requirements...more

Latham & Watkins LLP

Agencies Issue Guidance for Banking Organizations on Managing Risk in Third-Party Relationships

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The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. On June 6, 2023, the Federal Deposit Insurance Corporation...more

Sheppard Mullin Richter & Hampton LLP

FDIC, FRB & OCC Issue Final Guidance on Risk Management for Third-Party Relationships

On June 6, the FDIC, FRB & OCC issued final interagency guidance intended to assist their respective supervised banking organizations in identifying and managing risks associated with third-party relationships and in...more

Cadwalader, Wickersham & Taft LLP

Banking Agencies Finalize Interagency Guidance on Third-Party Risk Management

On June 6, the three Federal bank regulatory agencies (the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)), issued final interagency...more

Paul Hastings LLP

Daily Financial Regulation Update -- Saturday, May 27, 2023

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U.S. House Financial Services Committee Chairman Patrick McHenry (NC-10) sent a letter to Secretary of the Treasury Janet Yellen regarding Treasury's rumored Executive Order on outbound investment to China....more

Latham & Watkins LLP

White House Recommends Stricter Regulations for Large Regional Banks

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President Biden is calling for tougher standards and supervision for large regional banks in the wake of recent instability in the US banking sector. On March 30, 2023, the White House issued a Fact Sheet calling on the...more

Cadwalader, Wickersham & Taft LLP

FRB and OCC Release 2023 Stress Test Scenarios

The Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) last week released their 2023 Dodd-Frank Act Stress Test (“DFAST”) scenarios. As noted in the FRB’s release, the “stress tests help...more

White & Case LLP

A New “Operation Choke Point”? The Quickly Changing Rules on Crypto Activities for Member Banks

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In an effort to align the permissibility of crypto activities for all member banks of the Federal Reserve System (the "FRS", which includes all national banks and state member banks), the Board of Governors of the Federal...more

Orrick, Herrington & Sutcliffe LLP

Agencies release hypothetical scenarios for 2023 bank stress tests

On February 9, the Federal Reserve Board and the OCC released hypothetical economic scenarios for use in the upcoming stress tests for covered institutions. The Fed released supervisory scenarios, which include baseline and...more

Cadwalader, Wickersham & Taft LLP

FRB and FDIC Issue Joint ANPR on Possible Resolution Requirements for Large Banking Organizations While FRB and OCC Approve U.S....

The Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) Board issued an Advanced Notice of Proposed Rulemaking (“ANPR”) titled “Resolution-Related Resource Requirements for Large Banking...more

Cadwalader, Wickersham & Taft LLP

FRB Vice Chair Brainard Touts CRA Proposal and Positive Impacts on Native American Communities

On July 19, Federal Reserve Board (“FRB”) Vice Chair Lael Brainard gave remarks to the National Native Coalition Virtual Series sponsored by the National Congress of American Indians. Her remarks focused on the joint proposal...more

Cadwalader, Wickersham & Taft LLP

In Depth: A Look at Federal Banking Agencies’ Proposal to Update Community Reinvestment Act Rules

As we mentioned briefly in our newsletter last week, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”)  and the Office of the Comptroller of the Currency (“OCC”) (together, “The Agencies”)...more

Pillsbury Winthrop Shaw Pittman LLP

Federal Banking Regulators Propose Overhaul of Community Reinvestment Act

Regulators took a first step toward modernizing CRA regulations with a joint Notice of Proposed Rulemaking. The proposed rule would add more standardized metrics for regulators’ CRA examinations and more clearly delineate...more

Cadwalader, Wickersham & Taft LLP

Federal Banking Agencies to Issue Notice of Proposed Rulemaking to Amend Uniform Rules of Practice and Procedure

On March 22, the Federal Reserve Board issued a Notice of Proposed Rulemaking (“NPR”) that will be joined by the Federal Deposit Insurance Corporation, National Credit Union Administration and the Office of the Comptroller of...more

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