Financial Services Spotlight

December 2016 Developments

Posted by Roy Andersen on Jan 5, 2017 12:00:00 PM

Overview

The banking agencies did not appear to be participating in the supposed frenzy of rulemaking that has been prompted by the Trump election. In one of the few instances in history where powers of banks were actually reduced, banks were restricted in their dealings with industrial metals.  The CFTC proposed and adopted a variety of year-end regulations including related to position limits and aggregation of positions.  Big banks are bearing the brunt of regulatory focus including new final  rules on deposit account recordkeeping and disclosure of liquidity coverage. 

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Topics: Iran, Foreign Securities, National Banks, Qualified Financial Contracts, Small Banks, NCUA

November 2016 Developments

Posted by Roy Andersen on Dec 12, 2016 12:00:00 PM

Overview

The CFPB issued another mega-rule on prepaid accounts—subjecting the industry to hundreds of pages of new rules.  Flood insurance rules were changed to accept private flood insurance coverage.  North Korea was named as a country of primary money laundering concern and this triggers certain actions for banks.

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Topics: Sudan, North Korea, Iran, CFTC, Liberia, Regulation I, Consumer Compliance Rating System

March 2016 First Half Developments

Posted by Roy Andersen on Mar 16, 2016 12:00:00 PM

Overview

FinCEN published changes to the rules governing FBARs.  The change that may require more work is for those institutions that control more than 25 foreign accounts because more information will need to be reported with regarding to those accounts. The nuclear agreement with Iran resulted in dozens of changes to the SDN List and OFAC has published a comprehensive list of changes, most of businesses that are now authorized to engage in increased business activities.  Credit Unions continue to make inroads on banking activities and a new rule was adopted to liberalize commercial lending activities. Such lending is still an overall small percentage of credit union business but it is the fastest growing segment of credit union activity.

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Topics: OFAC, Ukraine, Iran, FBARs, Foreign Bank Accounts, Zimbabwe, Venezuela, Foreign Banking, Money laundering, FinCEN, Credit Union Commercial Loans, Terrorism Risk Insurance

January 2016 Second Half Developments

Posted by Roy Andersen on Feb 5, 2016 12:00:00 PM

Overview

Longstanding OFAC rules were changed regarding Iran and Cuba.  The Cuban sanctions were the first imposed by the Treasury in the 60’s and have been the model for sanctions programs since then.  Given the results of the 50- plus-year restriction on the Cuban economy it is safe to say that their economy simply stopped working and the Cuban people have eked out a living under mid-last century conditions.   Of course, a socialist economy may have also contributed to the dire circumstances.   If Iran truly abandons its nuclear program, then the leverage provided by the sanctions proves for all time their value as a political tool and another reason not to resort to war.  Treasury provided a concise up-to-date description of the Treasury securities market that was educational for me-- whose last real understanding of that market was forged when primary dealers ran the show.

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Topics: SEC, Iran, Cuba, Foreign Banking, OFAC rules, JCPOA

About the Spotlight


The Financial Services Spotlight examines the regulatory and technology developments impacting banks, asset managers and other financial services providers—where challenges meet opportunities.

 

Meet the Authors


Roy C. Andersen, of counsel in Sullivan & Worcester's New York office, is a member of the Corporate Department. Mr. Andersen focuses on bank regulatory and compliance matters, including international banks and their branches and agencies in New York.

Joel Telpner, partner in the firm's New York office, is a seasoned advisor, strategist and problem solver. Mr. Telpner brings more than 30 years of legal experience in a career that includes time as an AmLaw 100 partner, the former U.S. general counsel of a global financial institution, and a venture capitalist. He is recognized for his ability to deftly manage complex financial transactions, especially those involving sophisticated structured finance and derivatives matters and has an extensive and unique combination of transactional and regulatory experience.

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