At the intersection of sophisticated financial services practices and innovative technology, Perkins Coie lawyers offer unique perspective on the complex regulatory, business, and legal requirements facing financial services companies.
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Publications
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02.29.2024CFPB Issues Proposed Open Banking RuleArticlesThe Consumer Financial Protection Bureau announced that it was issuing a Notice of Proposed Rulemaking regarding Personal Financial Data Rights on October 19, 2023. The proposed rule would implement section 1033 of the Consumer Financial Protection Act of 2010, which gives consumers the right to access their financial data and authorizes third parties to access it on their behalf.
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12.20.2023FINRA’s In-House Courts Facing Challenges, Jarkesy Ripple EffectIn a commentary for Bloomberg Law, Rachel Mechanic and Daniel Zinman explain how FINRA's in-house tribunal system is defending constitutional challenges and may also have to navigate repercussions from a Supreme Court securities case.
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12.06.2023Treasury Releases First Installment of Long-Awaited Guidance on Donor-Advised FundsUpdatesOver the past several years, the U.S. Department of the Treasury has been preparing guidance concerning donor-advised funds, which are accounts owned and controlled by public charities over which individual or corporate donors may exercise advisory privileges. In November, Treasury finally released the first of four pieces of guidance that it has told practitioners to expect.
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12.04.2023The Corporate Transparency Act: What To Know and Expect Starting January 1, 2024UpdatesBeginning January 1, 2024, the Corporate Transparency Act will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and control persons to the U.S. Department of the Treasury Financial Crimes Enforcement Network.
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09.07.2023CFPB Announces Decision To Launch Rulemaking Targeting Data BrokersUpdatesFollowing a related request for information earlier this year, the Consumer Financial Protection Bureau announced on August 15, 2023, its intention to launch rulemaking targeting data brokers.
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08.01.2023Prepare to Comply With Upcoming Corporate Transparency Act Reporting RulesArticlesDomingo Such and Jamie Schafer wrote an article published in Trust & Estates titled "Prepare to Comply With Upcoming Corporate Transparency Act Reporting Rules" about the implications family offices and their advisors should be aware of regarding new reporting rules stemming from the Corporate Transparency Act.
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06.06.2023Final Interagency Third-Party Risk Management Guidance Issued on June 6, 2023: Implications for Banks and FinTech CompaniesArticles
Perkins Coie LLP
There is an adage among regulators, “same risks, same rules” or “leveling up,” and on June 6 the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (FRB), and Federal Deposit Insurance Corporation (FDIC) (together, the “Agencies”) issued final interagency guidance on managing the risks associated with third-party relationships (Final Guidance). -
03.27.2023CFPB Requests Information About Data Brokers for Planned RulemakingUpdatesThe Consumer Financial Protection Bureau announced on March 15, 2023, that it is issuing a Request for Information about the business practices of data brokers, which the agency said will assist it in “planned rulemaking” under the Fair Credit Reporting Act.
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03.17.2023Short-Term Cash Management AlternativesUpdatesA reference chart comparing certain key characteristics of demand deposits with government securities, money market funds, and other short-term cash management instruments. Please note that the chart is for informational purposes only and not for the purpose of providing legal or investment advice.
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02.06.2023Blockchain Brings Antitrust Concerns Alongside Competitive OpportunitiesUpdatesThe emergence of blockchain technology has heralded significant advances across an array of industries, from financial services to consumer goods. But there are two sides to every Bitcoin. This Update analyzes both the potential antitrust pitfalls and competitive opportunities associated with blockchain.
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09.12.2022CISA Seeks Input on New Cybersecurity Reporting RequirementsUpdatesPresident Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 on March 15, 2022. CIRCIA solicits public comment for 60 days, beginning September 12, 2022.
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03.02.2022Sanctioning Russia Over Invasion of UkraineUpdates
On February 21, 2022, Russian President Vladimir Putin unilaterally recognized the Luhansk and Donetsk regions in Eastern Ukraine as independent states.
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12.14.2021
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12.14.2021GLBA Safeguards Rule Updated to Impose New Data Security RequirementsUpdatesFollowing a 3-2 vote, the Federal Trade Commission recently announced amendments to the Safeguards Rule under the Gramm-Leach-Bliley Act.
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11.04.2021The Anti-Money Laundering Act of 2020: The Remarkable Expansion of the U.S. Government’s Subpoena Power Over Foreign Financial InstitutionsUpdatesOn New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA).
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09.21.2021AMLA 2020 Series Part 2: New Bank Secrecy Act Whistleblower ProvisionsUpdatesOn New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering, terrorism financing, and other illegal activities. In July, we examined the expansive new beneficial ownership reporting requirements added to the Corporate Transparency Act. In this second substantive installment of our multipart series on the AMLA 2020, we examine the changes made to the Bank Secrecy Act (BSA) whistleblower provisions.
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09.01.2021Dealing with the New Derivatives Rule: A Guide for Legal and Compliance ProfessionalsArticlesIn October 2020, the U.S. Securities and Exchange Commission (the SEC) adopted Rule 18f-4 under section 18 of the Investment Company Act of 1940 (the 1940 Act) to regulate the use of derivatives by open-end registered investment companies other than money market funds, business development companies (BDCs), and closed-end investment companies (Funds).
Presentations
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03.29.2023Regulatory Enforcement and Litigation: The Contagion Effect of FTX and Silicon Valley BankWebinarsThe webinar examined recent events, beginning with the Terraform Labs cryptocurrency collapse and continuing to the downfall of various entities, including FTX Trading Ltd. and Silicon Valley Bank. Our panel of experts addressed key legal and regulatory issues relating to these events.
