On July 5, 2021, the Financial Action Task Force (FATF), the global money laundering and terrorist financing watchdog, released its findings from a yearlong review documenting the progress that its member countries have made towards implementing its guidance on regulation of virtual assets and Virtual Asset Service Providers (VASPs).[1] In its 46-page report, the FATF concludes that the majority of its member countries have yet to incorporate the FATF’s virtual asset standards into their…

Financial Services Observer

FinCEN Identifies New Anti-Money Laundering (AML) National Priorities

By Carl A. Fornaris, Kyle R. Freeny & Marina Olman-Pal

July 6, 2021

On June 30, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in consultation with the U.S. attorney general, federal functional regulators, relevant state financial regulators, and relevant national security agencies, announced new federal anti-money laundering and counter–terrorism financing (AML/CFT) priorities, in accordance with the Anti-Money Laundering Act of 2020 (AML Act). Under the AML Act, once FinCEN promulgates regulations to implement these new AML/CFT priorities—which is expected to occur within the…

Financial Services Observer

Update: CFPB Finalizes Pandemic Mortgage Servicing Rules

By Benjamin M. Saul & Andrew S. Wein

June 30, 2021

On June 28, 2021, the Consumer Financial Protection Bureau (CFPB, or the Bureau) issued its Final Rule amending RESPA Regulation X to provide significant foreclosure protections to borrowers. Continue reading the full GT Alert.…

Financial Services Observer

Financial Services Insights | Spring 2021

By Greenberg Traurig, LLP

May 25, 2021

Welcome to the Spring 2021 issue of Greenberg Traurig’s Financial Services Insights Newsletter. This newsletter reviews certain significant cases and legal developments affecting the financial services industry. In This Issue: Spotlight on… GT Insights Upcoming Events Q&A with GT’s Ben Saul: Recent CFPB Developments and Outlook Sequel to Spokeo: Supreme Court to Address Standing and Typicality Requirements for Class Actions The Enhanced Whistleblower Provision of the AMLA 2020: Understanding and Meeting the Two-Fold Risk Continue reading …

Financial Services Observer

CFPB Reiterates Focus on Mortgage Industry COVID-19 Response, Highlights Fair Servicing Concerns

By Benjamin M. Saul & Andrew S. Wein

May 6, 2021

On May 4, 2021, the Consumer Financial Protection Bureau (CFPB or the Bureau) released two new reports that double down on its message in early April 2021 that the Bureau is heightening its supervisory and enforcement scrutiny of mortgage servicers. Continue reading the full GT Alert.…

Financial Services Observer

CFPB Intensifies Focus on Pandemic Mortgage Servicing

By Benjamin M. Saul & Andrew S. Wein

April 6, 2021

Hand touching Compliance Rules Law Regulation Policy Business Technology Interface

Over the last week, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) has sharpened its focus on the mortgage servicing industry. Knowing that millions of mortgage borrowers will exit COVID-19 moratoriums and forbearance plans in the fall, the Bureau first issued a compliance bulletin putting servicers on notice that it will use all supervisory and enforcement tools against those not ready to process loss mitigation requests from these borrowers. The CFPB followed by issuing…

Financial Services Observer

2021 SEC Examination Priorities for Securities Industry Registrants

By Richard M. Cutshall, Elaine C. Greenberg, Claudio J. Arruda, Arthur Don, Steven M. Felsenstein & Steve M. Malina

March 28, 2021

The Division of Examinations (the Division) (formerly known as the Office of Compliance Inspections and Examinations, or OCIE) of the U.S. Securities and Exchange Commission (SEC) released its annual list of 2021 Examination Priorities on March 3, 2021. Many of the Division’s 2021 examination priorities, including focus on conflicts of interest for brokers and investment advisers, among others, are perennial risk areas that the Division routinely prioritizes. While the SEC release discusses new issues in greater…

Financial Services Observer

2021 Report on FINRA’s Examination and Risk Monitoring Program

By William Mack, Richard M. Cutshall, Arthur Don & Douglas W. Hathaway

February 18, 2021

On Feb. 1, 2021, the Financial Regulatory Authority (FINRA) released its 2021 Report on FINRA’s Examination and Risk Monitoring Program (Report), in which it identifies its areas of examination focus for FINRA member firms (Firms) in 2021. The Report replaces the prior format for examination focus, the Risk Monitoring and Examination Program Priorities Letter. In the introduction to the Report, FINRA acknowledges the ongoing COVID-19 pandemic, its regulatory notice in response, and the challenges…

Financial Services Observer

SEC Staff Issues No-Action Relief for Custody of Certain Loan Interests Under the Investment Company Act

By Ryan F. Helmrich & Nathan M. Iacovino

February 17, 2021

On Jan. 13, 2021, the Division of Investment Management staff (Staff) of the Securities and Exchange Commission (Commission) issued a no-action letter advising that it would not recommend enforcement action to the Commission under Section 17(f) of the Investment Company Act of 1940 (1940 Act), and paragraphs (b)-(f) of Rule 17f-2 thereunder, if certain registered management investment companies or series thereof (Funds), or their directors or officers, if the Funds, acting as self-custodians, maintain certain…

Financial Services Observer

The Anti-Money Laundering Act of 2020: Congress Enacts the Most Sweeping AML Legislation Since Passage of the USA PATRIOT Act

By Carl A. Fornaris, Kyle R. Freeny, Marina Olman-Pal & Claudio J. Arruda

January 19, 2021

On Jan. 1, 2021, the U.S. Senate overwhelmingly voted (81-13) to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 20211, passing into law legislation that includes – as Division F – the Anti-Money Laundering Act of 2020 (AML Act).2 This GT Alert provides an overview of the important themes and significant provisions of the AML Act. Continue reading the full GT Alert, “The Anti-Money Laundering Act of 2020: Congress …

Financial Services Observer

News & Commentary on Financial Regulatory and Compliance Matters

Blog Authors

New Report Shows Majority of ‘Financial Action Task Force’ Countries Have Not Implemented Virtual Asset Guidance

FinCEN Identifies New Anti-Money Laundering (AML) National Priorities

Update: CFPB Finalizes Pandemic Mortgage Servicing Rules

Financial Services Insights | Spring 2021

CFPB Reiterates Focus on Mortgage Industry COVID-19 Response, Highlights Fair Servicing Concerns

CFPB Intensifies Focus on Pandemic Mortgage Servicing

2021 SEC Examination Priorities for Securities Industry Registrants

2021 Report on FINRA’s Examination and Risk Monitoring Program

SEC Staff Issues No-Action Relief for Custody of Certain Loan Interests Under the Investment Company Act

The Anti-Money Laundering Act of 2020: Congress Enacts the Most Sweeping AML Legislation Since Passage of the USA PATRIOT Act

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