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Bank Law Monitor

A legal blog for the financial services industry

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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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The STATES Act—A Solution to the Cannabis Banking Problem on the Horizon?
By Danielle Hunt, Kalin Bornemann, Olivia Grabacki, and Jessica Roberts As we previously discussed, financial institutions that offer financial services to the cannabis industry have been operating in a state of uncertainty in the wake of the rescis...
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Update: DOJ Rescinds the Cole Memo—FinCen Guidance Still in Effect, For Now…
In the wake of the shift in federal marijuana enforcement policy, financial institutions have been left to speculate the risk in offering financial services to marijuana-related businesses. While the U.S. Treasury Department's Financial Crimes Enforc...
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DOJ Rescinds the Cole Memo—What It Means for Your Financial Institution
Reiterating that Congress considers marijuana to be a "dangerous drug" and marijuana activity to be a "serious crime," Attorney General Jeff Sessions today issued a memo to all U.S. attorneys rescinding various memoranda related to enforcement of fed...
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