As previously discussed in the Roundup, the SEC has adopted amendments to the definitions of “accredited investor” and “qualified institutional buyer” (QIB). The amendments are substantially the same as those originally proposed by the SEC in December 2019, and will expand investor access to private capital markets by adding new categories of natural…
The SEC has adopted the third group of amendments to its disclosure requirements, originally proposed in August 2019 and discussed in an earlier Goodwin client alert. These amendments are the next steps as the SEC continues to update its disclosure requirements and will incrementally simplify disclosure about a company’s business, emphasizing a principle-based approach. Read…
In order to streamline its regulations, the FDIC has proposed to rescind and remove from the Code of Federal Regulations prompt corrective action rules that were transferred to the FDIC from the OTS on July 21, 2011, in connection with the implementation of Title III of the Dodd-Frank Wall Street Reform and…
On September 29, the Board of Governors of the Federal Reserve System (Federal Reserve), Office of the Comptroller of the Currency and FDIC finalized rules to provide COVID-19-related relief on appraisals and the liquidity coverage ratio. Both rules are either identical or substantially similar to interim final rules currently in…
On September 25, the FSOC released a Statement on Activities-Based Review of Secondary Mortgage Market (Statement). According to the Statement, in conducting its review, the FSOC evaluated the FHFA’s proposed new capital rule (Proposed Capital Rule) that is intended to enhance the quality and quantity of required capital so as to ensure that each…
The staff of the SEC’s Division of Corporation Finance has issued a new compliance and disclosure interpretation under the Regulation S-K Compliance & Disclosure Interpretations (C&DIs) to provide guidance on whether benefits provided to executive officers because of the COVID-19 pandemic are perquisites or personal benefits under Item 402(c)(2)(ix)(A) of Regulation S-K….
On September 21, the Office of the Comptroller of the Currency (OCC) published an interpretive letter clarifying the authority of national banks and federal savings associations to hold “reserves” on behalf of customers who issue certain stablecoins (cryptocurrency backed by an asset such as a fiat currency, including U.S. dollars or other…
On September 16, FinCEN issued an Advanced Notice of Proposed Rulemaking to solicit comments on questions pertaining to potential regulatory amendments under the Bank Secrecy Act (BSA), which would require financial institutions to maintain “effective and reasonably designed” anti-money laundering programs. The amendments are intended to modernize the regulatory regime and provide…
On September 21, the Federal Reserve released an Advance Notice of Proposed Rulemaking (ANPR) soliciting public comment on its approach to modernizing regulations that implement the CRA. The ANPR seeks comment on the Federal Reserve’s proposals to meet low-to-moderate income banking needs by addressing changes in the banking industry and inequities in…
Goodwin’s recently held inaugural Global Survey on the State of Financial Technology shed light on some of the most pressing issues facing this vibrant sector at the intersection of capital and innovation. While the fintech sector continues to grow steadily, the results of our global survey suggest that much disruption…