Financial Services Spotlight

August 2016 Second Half Developments

Posted by Roy Andersen on Sep 8, 2016 12:00:00 PM

Overview

The OCC published a proposed rule dealing with qualified financial contracts and their effect on the U.S. financial system.   The proposal is similar to a rule proposed by the Federal Reserve earlier this year.  In essence, QFCs will be required to contain provisions that restrict acceleration and contain contractual stay provisions.  FinCEN is proposing to expand its requirements for AML programs to banks that are not currently subject to federal supervision.

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Topics: Whistleblowers, OCC, CFTC, Federal Housing Finance Agency, AML Program

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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