Category Archives: Client Alert

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The SEC and FINRA Double-Down on Cybersecurity Enhancement and Prevention

In the wake of recent cybersecurity breaches, the SEC and FINRA simultaneously issued reports this week to the securities industry summarizing cybersecurity examination findings and to investors recommending certain precautions to safeguard online investment information. In its Risk Alert – Cybersecurity Examination Sweep Summary, the SEC describes the results from examinations of more than 100 … Continue Reading

CFPB Observer: Recent Developments from Jan. 26-30, 2015

The authors discuss current developments with the Consumer Financial Protection Bureau (CFPB) including a proposed rule amending mortgage rules relating to small creditors, a Compliance Bulletin providing guidance on the CFPB’s regulations governing the use and disclosure of confidential supervisory information, and guidance on private student loans with graduated repayment terms. Continue Reading.… Continue Reading

AML Developments – FDIC Announces That It Will End Its Supervisory Trend of Expecting Regulated Institutions to ‘De-Risk’ Entire Categories of Customers

On Jan. 28, 2015, the Federal Deposit Insurance Corporation (FDIC) in a Financial Institutions Letter (FIL) announced that it would, in effect, do an about-face on its supervisory expectation that banks strongly consider discontinuing the provision of financial services to entire categories of certain purportedly high-risk customers. These categories of customers included, to name a … Continue Reading

Payments to Unregistered Persons – The Next Round

The role of the Financial Industry Regulatory Authority (FINRA) regarding payments to unlicensed persons for securities-related and capital-raising activities has expanded. This post gives an overview of the FINRA Rule 2040 (approved by the SEC on Dec. 30, 2014) which governs when and how registered broker-dealers can provide compensation to unregistered persons. Approval of Rule … Continue Reading

CFPB Observer: Recent Developments from Dec. 15, 2014 – Jan. 2, 2015

The authors discuss current developments with the Consumer Financial Protection Bureau (CFPB) including a report on college credit card agreements, a lawsuit against a national wireless carrier for third-party charges, an action against a retailer for unlawful debt collection practices, and an extension of the foreclosure protection period for servicemembers. Continue Reading.… Continue Reading

Congress Enacts Changes to Dodd-Frank; Potential for More Changes in 114th Congress

Prior to adjournment, the 113th Congress passed the first changes to the Dodd-Frank Wall Street Reform and Consumer Protection Act (P.L. 111-203, “Dodd-Frank”) since the landmark legislation was signed into law by President Obama on July 21, 2010. The changes partially repeal the “swaps push-out” rule and make clear the Federal Reserve Board’s authority to … Continue Reading