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…
On August 26, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Federal Reserve), and FDIC issued three final rules that are identical or substantially similar to interim final rules issued earlier this year in response to the effects of the COVID-19…
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…
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…
On August 28, the SEC amended and extended the temporary final rules adopted earlier this year that were intended to facilitate capital formation for small businesses impacted by the coronavirus pandemic. The temporary final rules will continue to provide limited, conditional relief from certain Regulation Crowdfunding requirements that relate to the timing of the…
On August 26, the SEC announced that the fees public companies and other issuers (including mutual funds) pay to register their securities with the SEC will decrease nearly 16% from $129.80 per million dollars to $109.10 per million dollars. The change will be effective this year on October 1. The fee rate…
On August 26, the SEC adopted amendments to the definition of “accredited investor” under Rules 501(a) and 215 of the Securities Act of 1933 (Securities Act) and adopted amendments to the “qualified institutional buyer” (QIB) definition under Rule 144A of the Securities Act. Historically, individual investors who do not meet specific income…