CECL Delayed for Small and Private Companies, But 2020 Implementation is Likely Here to Stay

By John Banes, Margaret E. Tahyar, Shane Tintle & Tyler Senackerib on July 19, 2019

The Financial Standards Accounting Board (FASB) voted on Wednesday to propose delaying the implementation date of the Current Expected Credit Losses accounting standard (CECL) until 2023, for all companies other than larger SEC filers. The proposal would reduce the number of implementation dates from three to two. Under the proposal, companies that must file or furnish financial statements with the SEC and which, in the most common fact pattern, have a market capitalization of more…

FinReg

U.S. Regulators Announce BSA/AML Enforcement Actions Against U.S. Broker-Dealers

By John Banes, Luigi L. De Ghenghi, Britt Mosman & Daniela Dekhtyar-McCarthy on January 2, 2019

As 2018 came to a close, U.S. financial regulators continued to pursue anti-money laundering (“AML”) enforcement actions against financial institutions, announcing monetary penalties against and resolutions with three U.S. broker-dealers. The Financial Crimes Enforcement Network (“FinCEN”), the Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) announced on December 17, 2018 that they had issued parallel fines against UBS Financial Services Inc. (“UBSFS”) totaling $14.5 million for willful failures to comply with…

FinReg

EU No-Deal Contingency Planning

By John Banes, Michael Sholem & Jennifer Duffy on December 19, 2018

On December 19, 2018 the European Commission published the legislative proposals and delegated acts (the “Package”) which it had previously outlined in its Contingency Action Plan of November 13, 2018 to prepare for a “no-deal” scenario whereby the UK exits the EU on March 29, 2019 without a ratified withdrawal agreement in place. The Package includes 14 measures in a number of areas where a no-deal scenario may create major disruption for citizens…

FinReg

FinCEN and Banking Regulators Issue Joint Statement on Innovation in BSA/AML Compliance

By John Banes & Britt Mosman on December 10, 2018

On December 3, 2018, a U.S. government working group aimed at improving the effectiveness and efficiency of the BSA/AML regime issued a second joint statement, which focuses on innovative industry approaches to BSA/AML compliance. This follows the working group’s first joint statement last month, which focused on BSA/AML resource sharing (as discussed in our prior blog post). The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and the federal banking regulators (the Board of Governors…

FinReg

Visual Memorandum: A New Cut – Federal Reserve and U.S. Banking Agencies Propose Tailored Regulatory Framework

By John Banes, Luigi L. De Ghenghi, Jai R. Massari, Gabriel D. Rosenberg, Margaret E. Tahyar & Greg Swanson on December 10, 2018

The move away from a one-size-fits-all regulatory framework based on asset size continues. On October 31, the Federal Reserve proposed a rule to implement Section 401 of the Economic Growth, Regulatory Relief and Consumer Protection Act, tailoring enhanced prudential standards for firms with $100 billion or more in total consolidated assets, and the three U.S. banking agencies proposed corresponding tailoring of their Basel III capital and liquidity rules. Overall, the proposals would: for U.S. GSIBs,…

Briefing: Governance

SEC Issues Updated Cybersecurity Guidance

By John Banes, Alan F. Denenberg, Joseph A. Hall, Michael Kaplan, Nicholas A. Kronfeld, James C. Lin, Byron Rooney & Richard D. Truesdell Jr. on February 23, 2018

On February 21, the Securities and Exchange Commission released updated interpretive guidance on cybersecurity disclosure, reaffirming staff guidance issued in 2011, providing more detailed guidance on disclosure of cybersecurity risks and incidents, advising companies to ensure that their disclosure controls and procedures take account of cybersecurity risks and noting the implications of cybersecurity incidents for insider trading prohibitions and Regulation FD compliance. The interpretive guidance lends the Commission’s imprimatur to the previously issued staff guidance…

John Banes

CECL Delayed for Small and Private Companies, But 2020 Implementation is Likely Here to Stay

U.S. Regulators Announce BSA/AML Enforcement Actions Against U.S. Broker-Dealers

EU No-Deal Contingency Planning

FinCEN and Banking Regulators Issue Joint Statement on Innovation in BSA/AML Compliance

Visual Memorandum: A New Cut – Federal Reserve and U.S. Banking Agencies Propose Tailored Regulatory Framework

SEC Issues Updated Cybersecurity Guidance

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