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Special Alert: NYDFS accelerates Libor transition planning
On December 23, 2019, the New York Department of Financial Services issued an “ Industry Letter ” requesting that each NYDFS-regulated institution submit the institution’s plan for addressing the transition away from Libor-based credit, derivative, and securities exposures. The NYDFS letter has...
Special AlertsSpecial Alert: OCC and FDIC issue CRA modernization proposal
On December 12, 2019, the OCC and the FDIC jointly issued a notice of proposed rulemaking (NPR) to modernize the regulatory framework implementing the Community Reinvestment Act. The NPR generally focuses on expanding and delineating the activities that qualify for CRA consideration, providing...
Special AlertsSpecial Alert: Banks no longer required to file SARs for hemp-related businesses
Federal and state banking regulators confirmed in a December 3 joint statement that banks are no longer required to file a suspicious activity report on customers solely because they are “engaged in the growth or cultivation of hemp in accordance with applicable laws and regulations.” * * * Click...
Special AlertsSpecial Alert: OCC and FDIC propose rules to override Madden
On November 18, 2019 the Office of the Comptroller of the Currency (“OCC”) issued a proposed rule to clarify that when a national bank or savings association sells, assigns, or otherwise transfers a loan, the interest permissible prior to the transfer continues to be permissible following the...
Special AlertsSpecial Alert: HUD, DOJ sign MOU on mortgage False Claims Act violations
On October 28, HUD and DOJ announced a long-awaited Memorandum of Understanding (MOU), which provides prudential guidance concerning the application of the False Claims Act to matters involving alleged noncompliance with FHA guidelines. The announcement was made by HUD Secretary Dr. Benjamin S...
Special AlertsSpecial Alert: California attorney general releases proposed CCPA regulations
Last week, the California attorney general released the highly anticipated proposed regulations implementing the California Consumer Privacy Act (CCPA). The CCPA — which was enacted in June 2018 (covered by a Buckley Special Alert ), amended several times and with the most recent amendments signed...
Special AlertsSpecial Alert: California Legislature passes several amendments to the California Consumer Privacy Act and other privacy-related bills
Lawmakers in California last week amended the landmark California Consumer Privacy Act (CCPA or the Act), which confers significant new privacy rights to California consumers concerning the collection, use, disclosure, and sale of their personal information by covered businesses, service providers...
Special AlertsSpecial Alert: CFPB issues Advance Notice of Proposed Rulemaking to end GSE patch
On July 25, the CFPB issued an Advance Notice of Proposed Rulemaking (ANPR) that is intended as a first step in an orderly expiration of the so-called GSE patch, which confers Qualified Mortgage status for loans purchased or guaranteed by Fannie Mae and Freddie Mac while those entities operate...
Special AlertsSpecial Alert: OFAC formalizes expectations for sanctions compliance programs
The U.S. Department of the Treasury’s Office of Foreign Assets Control last week issued a framework for OFAC Compliance Commitments , which, for the first time, outlines OFAC’s views on essential elements of a risk-based sanctions compliance program in a single document that can serve as a roadmap...
Special AlertsSpecial Alert: DOJ issues updated guidance for corporate compliance programs
On April 30, 2019, the Department of Justice Criminal Division released updated guidance on the Evaluation of Corporate Compliance Programs (the “Guidance”). The Guidance sets forth the non-binding factors that DOJ prosecutors utilize to evaluate a company’s compliance program and consequently...
Special Alerts