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On Oct. 3, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the “Agencies”) issued an interagency statement regarding the sharing of Bank Secrecy Act (“BSA”) resources (“Interagency Statement”). The Interagency Statement is directed at banks, and does not extend to other financial institutions…
On July 31, 2018, the Office of the Comptroller of the Currency (“OCC”) issued a news release announcing that it will begin accepting special purpose national bank (“SPNB”) charter applications from fintech companies that do not take deposits but are engaged in the business of lending money or paying checks (including the modern equivalent thereof, which the OCC suggests includes issuing debit cards or otherwise facilitating payments electronically). The OCC’s decision was announced shortly after the…
On Feb. 27, 2015, the Commodity Futures Trading Commission, Federal Deposit Insurance Corporation, Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, and Securities and Exchange Commission (collectively, the “Agencies”) published a new FAQ on the Agencies’ rule promulgated under Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which is commonly referred to as the “Volcker Rule.” The new FAQ now makes clear that the…
Yesterday, the Federal Reserve Board announced that it was granting a partial one-year extension of the Volcker Rule’s pending July 21, 2015 compliance deadline and said that it would grant an identical extension again next year. The extensions apply to the “covered funds” side of the Volcker Rule and give all banking entities until July 21, 2017 to conform any investments in, or relationships with, hedge funds and private equity funds to the requirements of…
On Dec. 10, 2013, the Commodity Futures Trading Commission (“CFTC”), Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (the “Board”), Office of the Comptroller of the Currency and Securities and Exchange Commission (“SEC”) (collectively, the “Agencies”) issued a final rule (the “Final Rule”) implementing Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), which is commonly referred to as the “Volcker Rule.” The Volcker Rule restricts the proprietary trading and…
On Dec. 10, 2013, the CFTC, FDIC, Federal Reserve Board, OCC and SEC issued a final rule (the “Final Rule”) implementing Section 619 of the Dodd-Frank Act, which is commonly referred to as the “Volcker Rule.” The Volcker Rule restricts the proprietary trading and private investment fund activities of U.S. banks and their affiliates, as well as foreign banks with a branch or agency office in the United States and their affiliates (collectively, “banking entities”).…
On Dec. 10, 2013, the CFTC, FDIC, Federal Reserve Board, OCC and SEC issued a final rule (the “Final Rule”) implementing Section 619 of the Dodd-Frank Act, which is commonly referred to as the “Volcker Rule.” The Volcker Rule restricts the proprietary trading and private investment fund activities of U.S. banks and their affiliates, as well as foreign banks with a branch or agency office in the United States and their affiliates (collectively, “banking entities”).…
The Commodity Futures Trading Commission (“CFTC”), the Federal Deposit Insurance Corporation (“FDIC”) and the Federal Reserve Board (“Fed”) each announced today that they will discuss, and potentially approve, a final draft of the Volcker Rule at their respective meetings on Tuesday, Dec. 10, 2013. The CFTC meeting will commence at 9:30 a.m. and the others at 10:00 a.m. Interested parties may view the proceedings of each meeting via the Internet. Information regarding these meetings and…