Category Archives: banking

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Interagency Guidance for Financial Institutions on Coronavirus Disease-Related Loan Modifications

On Sunday night, March 22, 2020, the federal banking agencies (OCC, FDIC, NCUA, Federal Reserve), the Consumer Financial Protection Bureau and the State Conference of Bank Supervisors issued an Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers Affected by the Coronavirus. The Guidance does two key things: 1. Short-term loan … Continue Reading

All Systems Go? LIBOR Transition Efforts During the COVID-19 Pandemic

As the COVID-19 situation continues to evolve, market volatility, workplace disruptions and a shuttering of everyday life are becoming increasingly commonplace. While the 2021 LIBOR phase-out may not seem top of mind during the current crisis, speculation is mounting about whether the pandemic will delay or otherwise alter the phasing out of the “world’s most … Continue Reading

FDIC and OCC Extend Comment Period for Proposed Changes to the Community Reinvestment Act Regulations

On Feb. 19, the Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency (collectively, the “Agencies”) announced an extension of the public comment period on the Notice of Proposed Rulemaking (NPRM) to amend the regulations implementing the Community Reinvestment Act (CRA). The Agencies announced they are extending the public comment deadline to … Continue Reading

LIBOR Transition Newsletter – Issue 1

Welcome to Greenberg Traurig’s LIBOR Transition Newsletter, where we provide updates, analysis, and occasional commentary on the latest developments relating to the highly anticipated phasing-out of LIBOR at the end of 2021 – barely two years from now. Questions addressed in this issue: Why is LIBOR being phased out? What will be the immediate effect? … Continue Reading

Joint Statement Emphasizes Risk-Focused Approach to Examinations of Banks’ BSA/AML Compliance Programs

On July 22, 2019, the federal bank regulatory agencies and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (collectively, the “Agencies”), issued a Joint Statement on Risk-Focused Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Supervision. The Joint Statement emphasizes their risk-focused approach to examinations of banks’ BSA/AML compliance programs and is the third statement from … Continue Reading

Amendments to ‘Volcker Rule’ to Exclude Certain ‘Small’ Banks From Key Prohibitions

In connection with the U.S. financial crisis 10 years ago, legislation was adopted to enhance the safety and soundness of the commercial banking system in the United States. Amendments to the Bank Holding Company Act of 1956 required five federal financial agencies to adopt joint regulations to (i) limit the authority of commercial banking institutions to … Continue Reading

When Can Futures Commission Merchants and Broker-Dealers Be Deemed Banks?

On March 21, 2019, in Whitaker v. Wedbush Securities, an Illinois appellate court for the first time addressed the liability of a futures commission merchant (FCM) or broker-dealer (BD) under Section 4A-105 of the Uniform Commercial Code (UCC). By way of background, a customer of an FCM dually registered as a BD ostensibly requested a … Continue Reading
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