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Bank Law Monitor

A legal blog for the financial services industry

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Banking Regulators Encourage Lenders to Work with Borrowers Impacted by COVID-19
Federal banking regulators took a bold, first step this past Sunday, announcing Interagency Guidance ("the Guidance") to encourage lenders to work with borrowers impacted by the COVID-19 outbreak.[1] The Guidance specifically permits lenders to enter...
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Hemp-Banking Guidance Leaves a Lot of Questions
The financial services industry has been waiting with bated breath for guidance from its regulators on banking hemp and hemp-derivatives like CBD. On Tuesday, December 3, federal regulators issued a joint statement attempting to “provide clarity” on...
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Bankers Beware—Trade Secret Misappropriation Can Lead to Lifetime Ban
Employees change jobs all the time. There is generally nothing wrong with an employee planning his or her next move while still employed. But when an employee’s plans include gathering up his or her employer’s trade secrets to use at a new place of e...
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FinCEN Reverses Course on Beneficial Ownership Requirements in Connection with Loan Renewals and Modifications
It can be hard for regulatory agencies to admit when they’ve made a mistake. But that’s exactly what FinCEN did last week when it announced that certain loan renewals and modifications[1] would not trigger its beneficial ownership due diligence rule...
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The Shifting Sands of Washington’s Consumer Loan Act
Since the Great Recession, the regulation of residential mortgages and those who service them have been in sharp focus. Legislators and regulators continue to demonstrate an abiding mistrust in the servicing industry a full decade after the financial...
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The OCC Doubles Down on Fintech Banks
Traditional banks and lenders may soon see some increased competition from actors in the financial technology industry. As we previously discussed, the Office of the Comptroller of the Currency (OCC) has led the regulatory charge by inviting so-calle...
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