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Dec 11, 2024 | 
arnoldporter.com | Soo-Mi Rhee |Kevin Toomey |Junghyun Baek |Trevor G. Schmitt
On November 26, 2024, the U.S. Court of Appeals for the Fifth Circuit held in Van Loon v. Department of the Treasury that the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) exceeded its statutory authority by designating Tornado Cash — a decentralized, open source software protocol that facilitates anonymous cryptocurrency transactions — on its Specially Designated Nationals and Blocked Persons List (SDN List).
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Dec 11, 2024 | 
arnoldporter.com | Kevin Toomey |Jami Vibbert |Nancy Perkins |Anthony Raglani
The Consumer Financial Protection Bureau (CFPB) recently released a report identifying limits in federal privacy protections afforded by the Fair Credit Reporting Act (FCRA) and Gramm-Leach-Bliley Act (GLBA). The report strongly encourages state policymakers to consider how consumers are impacted by the FCRA and GLBA exemptions contained in all of the 191 broad state consumer privacy laws enacted over the past six years.
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Sep 27, 2024 | 
mondaq.com | Veronica E. Callahan |Ellen K. Fleishhacker |Michael Mancusi |Kevin Toomey
On August 28, 2024, the Financial Crimes Enforcement Network
(FinCEN) issued a final rule to add "investment
adviser" to the definition of "financial
institution" under the regulations implementing the Bank
Secrecy Act (BSA).
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Aug 26, 2024 | 
mondaq.com | James Bergin |David Freeman |Michael Mancusi |Kevin Toomey
On July 25, 2024, the Board of Governors of the Federal Reserve
System (the Federal Reserve), the Federal Deposit Insurance
Corporation (the FDIC), and the Office of the Comptroller of the
Currency (OCC) (together, the Federal Regulators) issued a joint
statement on banks' arrangements with third parties to deliver
bank deposit products and services (the Joint Statement).
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Aug 22, 2024 | 
arnoldporter.com | Kevin Toomey |Robert Azarow |James Bergin |Amber Hay
On July 30, 2024, the Board of Directors of the Federal Deposit Insurance Corporation (FDIC) approved a proposal to amend its existing regulations governing parent companies of industrial banks and industrial loan companies (collectively, industrial banks). In December 2020, the FDIC formalized its framework for supervising industrial banks in part 354 of the FDIC Rules and Regulations (Part 354).
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Aug 21, 2024 | 
arnoldporter.com | James Bergin |David Freeman |Michael Mancusi |Kevin Toomey
On July 25, 2024, the Board of Governors of the Federal Reserve System (the Federal Reserve), the Federal Deposit Insurance Corporation (the FDIC), and the Office of the Comptroller of the Currency (OCC) (together, the Federal Regulators) issued a joint statement on banks’ arrangements with third parties to deliver bank deposit products and services (the Joint Statement).
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Jul 19, 2024 | 
mondaq.com | Robert Azarow |Jane Norberg |Kevin Toomey |Paul Nabhan
On June 24, 2024, Eric Gerding, Director of the Division of
Corporation Finance (the Division) of the U.S. Securities and
Exchange Commission (SEC), published a statement regarding certain areas of focus
within the Division's Disclosure Review Program. While Director
Gerding discussed areas applicable to all industries, his statement
put banking registrants on alert regarding disclosures of risks
related to their commercial real estate (CRE) exposure and the use
of artificial intelligence (AI).
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Jul 18, 2024 | 
arnoldporter.com | Robert Azarow |Jane Norberg |Kevin Toomey |Paul Nabhan
On June 24, 2024, Eric Gerding, Director of the Division of Corporation Finance (the Division) of the U.S. Securities and Exchange Commission (SEC), published a statement regarding certain areas of focus within the Division’s Disclosure Review Program. While Director Gerding discussed areas applicable to all industries, his statement put banking registrants on alert regarding disclosures of risks related to their commercial real estate (CRE) exposure and the use of artificial intelligence (AI).
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Jul 17, 2024 | 
mondaq.com | Amber Hay |David Freeman |James Bergin |Kevin Toomey
During the meeting of the Board of Directors (Board) of the
Federal Deposit Insurance Corporation (FDIC) in June, the Board
unanimously adopted a resolution that requires FDIC staff
to provide full Board briefings for merger and deposit insurance
applications (each, a Covered Application) that have been
outstanding for more than 270 days.
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Jul 17, 2024 | 
mondaq.com | David Freeman |Kevin Toomey |Robert Azarow |Amber Hay
CONTRIBUTING SINCE FEBRUARY 2015
Arnold & Porter is a firm of more than 1,000 lawyers, providing sophisticated litigation and transactional capabilities, renowned regulatory experience and market-leading multidisciplinary practices in the life sciences and financial services industries. Our global reach, experience and deep knowledge allow us to work across geographic, cultural, technological and ideological borders.
