Legal

SWOT-ing at the crisscrossing crypto crackdown

8/1/2022
Using the tried-and-true SWOT analysis, banks can establish a baseline to evaluate the impact the crisscrossing crypto crackdown will have on their internal and external environment.

Cybersecurity Incident Rule – a household good

6/1/2022
Banks will need to update their response plan communication guidelines to document how, when, to whom and by whom notice of a “notification incident” would be provided.

Computer-Security Incident Notification final rule: What you need to know

3/30/2022
Banks will need to update their response plan communication guidelines to document how, when, to whom and by whom notice of a “notification incident” would be provided.

FinCEN seeks comments on changes to beneficial ownership reporting

1/31/2022
The availability of beneficial owner information to financial institutions with customer due diligence obligations would be practical and useful.

Challenging year sets stage for 2022

12/6/2021
TBA's engagement strategy matured in 2021 and we were able to influence the legislation. This was a good exercise and perhaps a preview of what’s in store for Texas bankers in 2022. A significant political year lies ahead.

OCC releases proposal to rescind CRA final rule

12/6/2021
Banks that changed type based on the asset threshold adjustments in the June 2020 Rule are subject to different performance standards for activities conducted on or after October 1, 2020.

The reform and modernization of BSA/AML

10/1/2021
With technology changing and growing at what seems like the speed of light, banking laws and regulations can struggle to keep up.

The OCC reconsiders going it alone on CRA

9/1/2021
On July 20, 2021, the OCC announced it will propose to rescind the agency’s May 2020 final rule overhauling the CRA, signaling the OCC’s intention to collaborate with the Fed and the FDIC on a separate joint rulemaking.

The black and white of TRID timing

8/1/2021
There are so many ways to violate TRID. Mastering the content requirements (knowing what to put where) is a difficult task for even the most seasoned compliance professional and is the source of numerous violations.

Mortgage borrowers amidst the pandemic 2021 and onward

7/1/2021
Banks should be prepared for a larger regulatory emphasis on COVID-19 protections and fair lending practices.

Regulators release new flood insurance Q&As

6/1/2021
The financial regulatory agencies (OCC, Fed, FDIC, FCA and NCUA) have recently proposed revisions to the Interagency Questions and Answers Regarding Flood Insurance.

87th Legislative Session proving pundits wrong again

5/1/2021
Conventional wisdom and the pundits predicted that the 87th Regular Session would be a low bill session. With more than 7,001 bills filed to date, the pundits have been proven wrong.

What banks need to know when providing financial services to hemp-related businesses

4/1/2021
The production of industrial hemp is a fast-growing industry, especially since the passing of the 2018 Hemp Bill, which clarified from a federal perspective that the cultivation of hemp is legal and no longer restricted to pilot programs for research

What are the implications of the NDAA?

3/1/2021
The NDAA includes more than 200 pages of significant reforms to the Bank Secrecy Act and other anti-money laundering laws putting forth the most comprehensive set of BSA/AML reforms since the USA PATRIOT Act of 2001.

AML/BSA reform is on the horizon

2/1/2021
When Congress pushed through the National Defense Authorization Act for fiscal year 2021, the banking industry was hopeful for the potential elimination of excessive regulatory burdens under the Bank Secrecy Act.

2021: An odyssey away from LIBOR

1/1/2021
More than three decades later, after determining that LIBOR was vulnerable to interest rate manipulation, it was announced that the benchmark rate would be discontinued beginning Dec. 31, 2021.

Legislating in the age of COVID

12/1/2020
Despite logistical concerns and operational challenges, 87th Legislature set to tackle budget, redistricting, criminal justice reform and other priorities

BSA/AML compliance strategies in a COVID-19 environment

12/1/2020
The federal regulators have been proactive in providing the banking industry with up-to-date compliance guidance relating to the pandemic.

The race is on! Keeping up with the BSA

11/1/2020
The federal regulators have been proactive in providing the banking industry with up-to-date compliance guidance relating to the pandemic.

Changes to eligible retained income

10/1/2020
In response to the potential economic effects of the coronavirus, the OCC, FRB and FDIC published an interim final rule March 20 proposing to revise the definition of eligible retained income.

E-sign considerations in mortgage lending

4/1/2020
More and more banks are taking applications, delivering disclosures and closing loans all online and without ever seeing the borrowers.

How to successfully define your target market

3/1/2020
Watching the Super Bowl is as much about the game as it is about the commercials. If you stop and think about it, all the commercials are geared to a target audience.

Modernization is in the works for CRA

2/1/2020
Modernization is in the works for CRA Just like a classic 1977 Chrysler Sunbeam, all great models need an overhaul from time to time. The Community Reinvestment Act is no exception.