On October 7, the CFPB published an FAQ on the Real Estate Settlement Procedures Act (RESPA) Section 8 and certain provisions of Regulation X, addressing common scenarios involving gifts, promotional activities and marketing services agreements (MSAs). The CFPB also rescinded Compliance Bulletin 2015-05 – RESPA Compliance and Marketing Services Agreements on the grounds that…
On October 16, the SEC announced that it adopted final amendments to certain auditor independence requirements in Rule 2-01 of Regulation S-X. The final amendments are based on recurring fact patterns that the SEC staff has observed over years of consultations in which certain relationships and services triggered technical independence rule violations…
On June 5, the Office of the Comptroller of the Currency (OCC) announced the issuance of a compliance guide for small banks to support implementation of its new Community Reinvestment Act (CRA) rule. The compliance guide summarizes the final rule, including: (1) compliance dates; (2) the types of activities that qualify for CRA consideration;…
On September 30, the Federal Reserve posted FAQs on its recently adopted control rule (Control Rule). The FAQs cover the calculation of issuer’s shareholders’ equity under the Control Rule, actions to be taken if an investment previously considered to be noncontrolling triggers one or more of the presumptions of control in the Control Rule,…
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…