Financial Services Spotlight

FFIEC Examination Procedures for the Beneficial Ownership Rule

Posted by Roy Andersen on May 16, 2018 3:04:27 PM

The FFIEC has updated its BSA/AML manual effective May 5, 2018, to add a section on the new legal entity due diligence requirements and to update the section of the manual on customer due diligence generally. The Fed published an SR Letter containing these updates for the legal entity beneficial ownership rule that became effective last week on May 11. 

The Fed noted that the FFIEC examination procedures will be used by all federal and state examiners. This memorandum summarizes the requirements of the beneficial ownership rule and what the regulatory examinations will cover. All bank procedures should cover these items at a minimum.

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Topics: FFIEC, Bank Regulations, Federal Reserve

How Does the Fed Want to Regulate Foreign Banks?

Posted by Roy Andersen on Mar 12, 2018 10:50:11 AM

On March 5, 2018, the Fed’s new Vice Chairman for Supervision, Randal Quarles, spoke at the Institute of International Bankers annual conference. He wanted to express his thoughts on the appropriate regulatory environment for foreign banks in the U.S.

He suggested that large foreign banks with complex U.S. operations contributed to instability in the U.S. during the financial crisis and required extraordinary support from the regulators. These same banks expanded dramatically just before the crisis, but the regulators did not adjust to the risks created by these activities. He suggested that these banks needed greater “resiliency” to meet challenging times.

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Topics: Financial Regulation, Federal Reserve

Proposed Fed Guidance for Bank Boards of Directors

Posted by Roy Andersen on Aug 7, 2017 10:05:29 AM

Yesterday the Fed published a proposed guidance document for its expectations for board of directors of banks. The release only applies to the boards of banks with over $50 billion in consolidated assets, but the intent of the Fed is to ease up on directors at all banks. The proposal was issued after an extensive review of the activities of bank boards and reflects independent directors’ dissatisfaction with the burdens that the regulators have been placing on bank directors.

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Topics: Banking, Bank Regulations, Supervision and Regulation, Federal Reserve

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.

The material on this site is for general information only and is not legal advice. No liability is accepted for any loss or damage which may result from reliance on it. Always consult a qualified lawyer about a specific legal problem.

 

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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