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Risk Management Banks

Troutman Pepper

Where the F(BO) Is the Money? Part 1 – Synapse’s Clarion Call for Standards

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This is the first of three articles focused on a key question: as bank-fintech partnerships continue to play a vital role in driving financial services, how does the industry make this system safer and better?...more

Sheppard Mullin Richter & Hampton LLP

Fed Issues Cease and Desist Order for Crypto-Related Compliance and Risk Management Deficiencies

On September 4, the Federal Reserve Board (Fed) released enforcement actions against a Texas-based bank, addressing regulatory violations and compliance lapses. The Fed, joined by the Texas Department of Banking (TDB),...more

A&O Shearman

Regulatory monitoring - August 2024

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1. Bank regulation - 1.1 PRUDENTIAL REGULATION - a) General - (i) EU - EBA: Opinion on measures in accordance with Article 458 CRR following a notification by the De Nederlandsche Bank - Status: Final - The EBA has...more

Orrick, Herrington & Sutcliffe LLP

OCC announces enforcement actions for August 2024

On August 22, the OCC released a list of recent enforcement actions against national banks, federal savings associations, and individuals affiliated with such entities (defined as institution-affiliated parties, or IAPs). The...more

Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

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The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Why do Fintechs Want to Become Banks?

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A great number of fintechs are contemplating owning a bank or obtaining a banking charter—either a national bank charter, a state bank charter or a special purpose charter. In this episode, we are joined by our special guest...more

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

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The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

Cadwalader, Wickersham & Taft LLP

Banking Regulators’ Request for Information on Bank-Fintech Arrangements

On July 25, 2024, the Fed, the OCC and the FDIC (the “Banking Regulators”) released a “Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses” (the...more

Alston & Bird

Regulators Focus on Bank-Fintech Arrangements

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Through joint guidance and an information request, federal bank regulators underscored banks’ compliance responsibilities in their banking-as-a-service (BaaS) relationships with third parties. Our Financial Services Team...more

Troutman Pepper

FDIC Proposal Would Classify More BaaS Deposits as Brokered, Not Core

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“I would say a lot of these fintechs deposits are actually the opposite of hot money,” said Matthew Bornfreund, a partner at Troutman Pepper. “I think a problem with this proposed rulemaking is, the FDIC asserts that these...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

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On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Ballard Spahr LLP

Regulators Outline Risks that Third-Party Servicers Pose to Banks

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Banking regulators have issued a joint statement outlining the potential risks that financial institutions face in arrangements with third parties to deliver bank deposit products and services and examples of risk management...more

Troutman Pepper

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more

Cadwalader, Wickersham & Taft LLP

Summer Regulatory Round-Up | July 2024

The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more

GeoDataVision

How to Minimize Compliance Risk in the Radical New “Modern” Redlining Era

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As any bank professional regulatory compliance professional knows redlining is the hottest issue today and has been since Attorney General Merrick Garland announced the “Combatting Redlining Initiative” in October 2021. Since...more

Latham & Watkins LLP

OCC Proposes Updates to Large Bank Recovery Planning Guidelines

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OCC-supervised institutions with $100 billion or more in average total consolidated assets must be adequately prepared to mitigate severe financial and non-financial risks. ...more

Lippes Mathias LLP

Navigating Private Lending: Best Practices for Success

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In times of economic uncertainty, lending is not exclusively within the realm of banks. Non-financial institutions, such as corporate entities, pension funds, insurance companies, and even high-net-worth individuals, play a...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

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As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

Patomak Global Partners

Stress Test Results Keep Risk Management Capabilities in Focus

Situation Overview: The Federal Reserve Board (FRB) uses the stress tests as a key supervisory tool to explore risks across large banks. This year’s results quantified the impact to banks under multiple new scenarios,...more

Sheppard Mullin Richter & Hampton LLP

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more

Poyner Spruill LLP

The First Bank to Collapse in 2024: What Led to the Failure of Republic Bank

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The first bank to meet its demise in 2024 is smaller than its 2023 counterparts. In 2023 we saw Silicon Valley Bank (“SVB”) and First Republic Bank (“First Republic”) fail. The most recent bank to experience a failure bears a...more

Woodruff Sawyer

The Growing Cyber Risks in Fintech and How to Mitigate Them

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The fintech revolution has reshaped the financial world, creating new opportunities to borrow, save, transact, and invest like never before. With no signs of slowing, fintech revenues are projected to grow sixfold from $245...more

Cooley LLP

Building Cyber Resilience in the Financial Services Sector: New Rules in Europe

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Key takeaways - DORA – The Digital Operational Resilience Act (DORA) is a European Union regulation that came into force on January 16, 2023 and will take effect on January 17, 2025. Its goal is to enhance information...more

Troutman Pepper

Federal Banking Agencies Issue New Guidebook for Community Banks Managing Third-Party Relationships

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On May 3, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (collectively, the agencies) released a guidebook aimed at assisting...more

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