Persons or entities that assemble or evaluate consumer credit information and furnish these consumer reports to third parties are consumer reporting agencies under the federal Fair Credit Reporting Act (FCRA). Consumer reporting agencies are responsible for clear...
On March 8, 2024, the Federal Reserve Board issued a final rule for supervised systematically important financial market utilities (FMUs), enhancing risk management standards, as well as safety and soundness. Once published in the federal register, FMUs are required...
Litigation and regulatory enforcement actions by federal and state regulators have dominated the news feeds in the past months. Review the Cryptocurrency and Litigation tracker, developed by Jason Gottlieb, Partner at Morrison Cohen LLP, for up to date information...
The Federal Deposit Insurance Corporation (FDIC) recently amended rules governing the use of FDIC signage, advertising statements, and insurance coverage misrepresentation. This article provides a comprehensive analysis of the changes to Subpart B of 12 CFR Part...
Rulemaking to implement the final components of Basel III (Basel III endgame) and the Federal Reserve Board’s GSIB surcharge is expected in 2024. The federal bank agencies proposed rules to strengthen capital requirements for large banks in 2023. Basel III...
Recent interagency guidance provides a framework for the risk management of climate-related financial risks for large financial institutions with over $100 billion in total consolidated assets. Explore this article addressing the federal banking agencies’...
Practical Guidance now offers a Mortgage Servicing Fees topic in the FSR state law comparison tool. The topic explores the statutory fee requirements in fifteen key U.S. states, with more coming soon. This question and answer series provides guidance on permissible...
The Office of the Comptroller of the Currency’s (OCC) recent proposal , released on January 29, 2024, seeks to update the rules for business combinations involving national banks and federal savings associations, and enhance transparency on the agency’s...
At the start of 2024, it remains to be determined whether U.S. securities laws apply to cryptoassets. In the absence of rulemaking by the Securities Exchange Commission (SEC), what makes a security is still an open question in the financial industry. Explore this...
Online businesses and merchants continue to explore accepting cryptocurrency as a form of payment for goods and services. The use of digital wallets by consumers makes the acceptance of cryptocurrency more widespread and impactful for banking organizations. Explore...
The Corporate Transparency Act (CTA) beneficial ownership information reporting began on January 1, 2024. CTA requires companies that are formed or registered to do business in the United States to file a beneficial ownership report with the Financial Crimes Enforcement...
The October 2023 revisions to the Community Reinvestment Act of 1977 (CRA) amend the CRA performance evaluation framework for assessing banks and updates the federal banking agencies’ consideration criteria. CRA was implemented to ensure that banking institutions...
Agency examinations are a fundamental part of supervising financial institutions and their third-party service providers. Instituted by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act), the Consumer Financial Protection Bureau...
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently released a Notice of Proposed Rulemaking (NPRM) calling for new reporting and recordkeeping requirements on convertible virtual currency (CVC) mixing transactions...
The compliance reporting date for businesses to begin reporting their beneficial owners’ information is quickly approaching. The Corporate Transparency Act (CTA) requires beneficial ownership information reporting to begin on January 1, 2024. Recent amendments...