Financial Services Spotlight

Review of Regulatory Responses to the Resolution Plans from the Big Foreign Banks

Posted by Roy Andersen on Jan 30, 2018 12:00:00 PM

Yesterday, the Fed and FDIC released their letters to the bigger foreign banks, i.e. the banks just below the UBS-level. The Fed’s letters were in response to the resolution plans filed in December of 2015. In these letters, the Fed and FDIC expressed what they expected in the next round of resolution plans from these banks due at the end of this year. The Fed conceded that even though these banks are huge, their U.S. activities are of "limited complexity." Only HSBC was given a laundry list of new items that the regulators expected to see in the 2018 Plan

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Topics: Regulatory Filings, FDIC, foreign banks, Resolution Plans

October and November Developments

Posted by Roy Andersen on Dec 8, 2017 8:40:22 AM

Overview

For the first time in my memory, the Congress passed a joint resolution to disapprove a final regulation of a federal agency—in this case the CFPB and the rule was related to arbitration clauses in contracts for consumer financial products. In addition, the agencies amended certain definitions under CRA and these changes should be reflected in CRA policies and procedures at banks. Both the OCC and FDIC published final rules on requirements for Qualified Financial Contracts and introduced required language for larger banks.

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Topics: CFPB, FDIC, Qualified Financial Contracts, Mortgage Servicing, QVC

May, June and July Developments

Posted by Roy Andersen on Aug 9, 2017 1:44:12 PM

With a straight face, President Trump has issued an executive order on June 20th that would expand Apprenticeship opportunities in the US in order to expand jobs. The CFTC has adopted some final rules on records administration and its whistleblower program. It has also introduced a new project to evaluate its system of rules to see where simplification is warranted. FinCEN is moving against a Chinese bank that helps North Korea.

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Topics: OFAC, CFTC, FDIC, FinCEN, Qualified Financial Contracts, NCUA, Consumer Financial Products

February 2016 First Half Developments

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

Overview

The BCFP published a Compliance Bulletin to remind banks that they must have reasonable written policies and procedures to insure that any consumer reporting data they pass on to consumer reporting agencies is accurate and complete.  This has been a requirement for some time, but the BCFP has notice an uptick in inaccurate date, particularly with regard to deposit account data.  Banks can expect increased focus on these procedures during the next consumer compliance examination.  After 7 years of review, the CFTC has determined that Korea has sufficient supervisory systems in place to permit certain Korean swaps entities to do business with U.S. persons.  OFAC is abandoning certain reporting requirements in connection with remittance transactions with Cuba.

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Topics: OFAC, Cuba, Currency Transaction, CFTC, BCFP, Korea, Credit Reporting, FDIC, Foreign Regulatory

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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