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Update: When Are Section 19 Application Required?

USA - November 8 2018 On November 1, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) issued modifications to its Statement of Policy (“SOP”) for applications...

Juan M. Arciniegas, Lisa M. Simonetti, Daniel C. McKay II, James M. Kane, Mark C. Svalina, Jennifer Durham King.


Bringing a Level of Clarity to the Interagency Biographical and Financial Report

USA - July 26 2018 On July 11, 2018, the Office of the Comptroller of the Currency (“OCC”), the Federal Deposit Insurance Corporation (“FDIC”) and the Board of Governors...

Juan M. Arciniegas, Lisa M. Simonetti, Daniel C. McKay II, James M. Kane, Mark C. Svalina, Jennifer Durham King.


Update: Regulatory Relief Passed by Congress

USA - May 23 2018 On May 22, 2018, the House of Representatives passed the bipartisan Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) (the...

Juan M. Arciniegas, Lisa M. Simonetti, Daniel C. McKay II, James M. Kane, Mark C. Svalina, Jennifer Durham King.


FinCEN Grants a 90-Day Exemption from the Beneficial Ownership Rule for Certain Financial Product Renewals and Rollovers

USA - May 17 2018 On May 11, 2018, compliance with the beneficial ownership rule became mandatory. In accordance with the rule, a covered financial institution must...

Juan M. Arciniegas, Lisa M. Simonetti, Daniel C. McKay II, James M. Kane, Mark C. Svalina, Jennifer Durham King.


The Beneficial Ownership Rule Becomes Effective Today

USA - May 11 2018 On May 11, 2018, the beneficial ownership rule became fully effective. While the rule was finalized on July 16, 2016, compliance was not mandatory...

Juan M. Arciniegas, Lisa M. Simonetti, Daniel C. McKay II, James M. Kane, Mark C. Svalina, Jennifer Durham King.