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Publications
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12.04.2023CFPB Proposes Federal Oversight of Digital Wallet and Payment App ProvidersUpdatesThe Consumer Financial Protection Bureau (CFPB) published a proposed rule on November 7, 2023, that, if finalized, would subject to its supervisory authority certain Big Tech firms and other nonbank companies operating in the payments sphere.
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11.07.2023
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08.29.2023FFIEC BSA/AML Exam Manual Updates—Implications for BanksUpdatesThe Federal Financial Institutions Examination Council released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual on August 2, 2023.
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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). -
03.16.2023Distressed Bank Update as of March 16, 2023UpdatesIn the three days since federal authorities announced sweeping measures to protect depositors of Silicon Valley Bank (SVB) and Signature Bank and help prevent additional bank failures (as discussed in our update of March 12, 2023), the U.S. banking system appears to have stabilized, at least temporarily.
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03.12.2023Distressed Bank Update as of March 12, 2023UpdatesAt 6:15 p.m. ET on March 12, 2023, the Department of the Treasury, Federal Reserve, and FDIC announced “actions enabling the FDIC to complete its resolution of Silicon Valley Bank, Santa Clara, California, in a manner that fully protects all depositors. Depositors will have access to all of their money starting Monday, March 13” (emphasis added).
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03.11.2023Silicon Valley Bank Update as of March 11, 2023UpdatesAn overview of the failure of Silicon Valley Bank (SVB) and what we expect to happen next. This reflects information as of 4:00 p.m. PT on March 11, 2023. We note that it is an evolving situation; we will provide updates as warranted in the coming days. Please contact your Perkins Coie lawyer or email SVBSupport@perkinscoie.com with questions or for assistance.
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09.19.2022Federal Reserve Issues Final Guidelines for Master Account AccessUpdatesThe Federal Reserve Board issued final guidelines for regional Reserve Banks to use when considering applications for Federal Reserve “master accounts”—deposit accounts that enable direct access to the Federal Reserve’s payment systems and provide critical infrastructure to financial institutions operating in the United States.
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09.09.2021FINRA, Federal Banking Agencies Issue Guidance on Third-Party Risk ManagementUpdatesRecent guidance from financial industry regulators reminds market participants to remain mindful of their business, compliance, and operational obligations when incorporating technology vendors as a fundamental part of their infrastructure.
Presentations
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04.27.2023The Way of the Future: Forging and Maintaining Relationships With TradFiSpeaking EngagementsConsensus / Austin, TX
