Bank Law Monitor
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Straight Talk About Community Banks
Context
As many of you know, I spent six years as a bank regulator in the Securities Disclosure Division of the OCC. Since moving out to the Northwest, I have had the privilege of being involved with several hundred community banks ranging from de no...
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CFPB Finds “Deceptive” Data Security Practices Without Consumer Harm and Requires Dwolla to Implement a Written Data Security Plan
On February 16, 2016, the Consumer Financial Protection Bureau (CFPB) issued a Consent Order relating to certain “deceptive” acts and practices of Dwolla, Inc., an Iowa based payment processor (Dwolla). Dwolla operates a software platform that enable...
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Confluence
Deal Talk
Well, it’s almost Spring and the flowers and deal talk are starting to bloom. We hear and see a lot of activity going on in the Western United States. Our sense is that this activity is being fueled by a confluence of factors: continuing lo...
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Monday Morning Quarterbacking
Back to the Future
As I prepare for a presentation at the WIB Annual Directors Conference, it strikes me that it has been seven years since the financial meltdown. While our economy has improved, it still has not completely recovered and the Fed and...
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The SEC’s New Pay Ratio Rule
The Securities and Exchange Commission (SEC) recently adopted a new executive compensation disclosure requirement which will require comparison of the compensation of a company’s CEO to that of a “median employee” of the company.
The pay ratio rule...
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Trust Law Modernization in Washington State
In 2015, two new laws relating to trust administration in Washington State have gone into effect that will make the state a more attractive jurisdiction in which to establish and administer trusts.
These new trust laws were the product of the Enterpr...
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