The financial services industry is subject to a regularly changing landscape of regulations and laws, driven in part by shifts in policy from regulators and lawmakers.

Goodwin’s FinReg + Policy Watch provides real-time updates and analyses focusing on regulation and policymaking. Issues are framed in an easy-to-digest manner, providing insight gained from our experience serving in key roles in government and advising clients across the industry.

Follow along as we deliver our take on the latest developments affecting the financial services community as well as the road ahead.

SEC Issues CD&I On Disclosure of Benefits Provided to Executive Officers Because of the COVID-19 Pandemic

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….

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OCC Clarifies That Federally Chartered Banks and Thrifts May Engage in Certain Stablecoin Activities

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…

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FinCEN Seeks Comments on Enhancing the Effectiveness of Anti-Money Laundering Programs

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…

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Federal Reserve Issues Proposed Rule on Modernizing CRA Regulations

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…

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Rule Change Extends the Deadline for Passing the Examination for Certain Categories of Broker Professionals

On August 28, FINRA filed with the SEC a notice of proposed rule change that would extend the 120-day period that certain individuals can function as a principal or Operations Professional without having successfully passed an appropriate qualification examination through December 31, 2020. Earlier this year, in response to COVID-19, FINRA provided…

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SEC Issues FINRA Proposal to Amend Membership Forms CMA and NMA

The Financial Industry Regulatory Authority (FINRA) has filed a proposed amendment to the standardized membership application forms, Form NMA (New Membership Application Form) and Form CMA (Continuing Membership Application Form). The proposed amendments are non-substantive and technical changes that are intended to conform with the amended Membership Application Program rules that create…

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