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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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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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Reg CC Goes “Paperless”: New Amendments Address Electronic Checks, Remote Deposit Capture, and Other Modern Banking Trends
Regulation CC first became law back in 1992. Yes, that was when Sir Mix-a-Lot was “back” on the top of the charts, audiences were eating up Silence of the Lambs, and bowl cuts were a thing. Times have changed, but oddly Reg CC hasn’t. Since 1992, Reg...
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