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HTMLNCUA Proposes Rule to Amend Chartering and Field of Membership Rules
Stephen F. Donahoe, Erich M. Hellmold, Michael A. Mancusi, Edward G. Olifer, Kevin M. Toomey; Kilpatrick Townsend & Stockton LLP;
Legal Alert/Article
May 15, 2014, previously published on May 12, 2014
On May 1, 2014, the National Credit Union Administration (the “NCUA”) published in the Federal Register a proposed rule to amend the associational common bond provisions of Appendix B to 12 C.F.R. Part 701, Chartering and Field of Membership Manual (the “Proposal”)....

 

Adobe PDFFederal Banking Agencies Issue Final Dodd-Frank Act Stress Test Guidance for MidSized Banking Organizations
Stephen F. Donahoe, Erich M. Hellmold, Aaron M. Kaslow, Michael A. Mancusi, Kevin M. Toomey; Kilpatrick Townsend & Stockton LLP;
Legal Alert/Article
March 21, 2014, previously published on March 19, 2014
On March 5, 2014, the Federal Reserve Board (the “FRB”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Office of the Comptroller of the Currency (the “OCC”) issued final supervisory guidance implementing the provisions of section 165(i) (2) of...

 

Adobe PDFFinCEN’s Exceptive Relief Allows Dealers in Foreign Exchange to A
Erich M. Hellmold, Michael A. Mancusi, Kevin M. Toomey; Kilpatrick Townsend & Stockton LLP;
Legal Alert/Article
March 20, 2014, previously published on March 18, 2014
On March 11, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued FIN-2014-R003, an administrative ruling clarifying the circumstances in which a dealer in foreign exchange may accept alternative travel documents as identification for a non-resident alien. FinCEN stated that...

 

Adobe PDFNew York Department of Financial Services Begins Accepting Applications for the Establishment of Regulated Virtual Currency Exchanges
Stephen F. Donahoe, Erich M. Hellmold, Aaron M. Kaslow, Michael A. Mancusi, Kevin M. Toomey; Kilpatrick Townsend & Stockton LLP;
Legal Alert/Article
March 20, 2014, previously published on March 18, 2014
On March 11, 2014, the New York Department of Financial Services (“NYDFS”) issued a public order (“Order”) announcing that the NYDFS will consider formal proposals and applications for the establishment of regulated virtual currency exchanges operating in New York. It is...

 

Adobe PDFBank Secrecy Act and Anti-Money Laundering Programs Continue to Result in Significant Penalties
Stephen F. Donahoe, Erich M. Hellmold, Aaron M. Kaslow, Michael A. Mancusi, Kevin M. Toomey; Kilpatrick Townsend & Stockton LLP;
Legal Alert/Article
February 20, 2014, previously published on February 19, 2014
Bank Secrecy Act (“BSA”) compliance, and in particular anti-money laundering (“AML”) controls, remains a focus of regulators as evidenced by record fines levied in recent weeks. On February 7, 2014, the Financial Industry Regulatory Authority, Inc. (“FINRA”)...

 

Adobe PDFNYDFS Bitcoin Hearing Set for January 28-29th in New York City
Erich M. Hellmold, Michael A. Mancusi, Kevin M. Toomey; Kilpatrick Townsend & Stockton LLP;
Legal Alert/Article
January 31, 2014, previously published on January 24, 2014
On January 23, 2014, the New York Department of Financial Services (“NYDFS”) released details relating to its public hearing on the regulation of virtual currencies, which will be held on January 28th and 29th in New York City. The two day hearing will consist of five panels, each...

 

Adobe PDFOCC Proposes Guidelines Establishing Heightened Standards for Large Institutions
Erich M. Hellmold, Michael A. Mancusi, Kevin M. Toomey; Kilpatrick Townsend & Stockton LLP;
Legal Alert/Article
January 31, 2014, previously published on January 24, 2014
On January 16, 2014, the Office of the Comptroller of the Currency (“OCC”) released a proposal establishing minimum standards for the design and implementation of a risk governance framework for large insured national institutions, insured federal savings associations, and insured...

 

Adobe PDFNew York Department of Financial Services Takes Next Step toward Regulation of Bitcoin
Ravi R. Desai, Erich M. Hellmold, Michael A. Mancusi, Kevin M. Toomey; Kilpatrick Townsend & Stockton LLP;
Legal Alert/Article
November 20, 2013, previously published on November 15, 2013
On November 14, 2013, the New York Department of Financial Services (“NYDFS”) issued a Notice of Intent (“Notice”) to hold a hearing on Bitcoin and other virtual currencies in their continued effort to establish the appropriate regulatory guidelines and standards for this...

 

Adobe PDFMitigating Fair Lending Risk
Christina M. Gattuso, Erich M. Hellmold, Michael A. Mancusi; Kilpatrick Townsend & Stockton LLP;
Legal Alert/Article
October 8, 2013, previously published on October 7, 2013
Fair lending, particularly the manner in which regulators interpret “disparate impact,” is a significant compliance issue for financial institutions and has recently been a major enforcement priority of federal agencies. The U.S. Department of Justice (“DOJ”) has commenced a...