Regulation

​​Innovation must be built on foundation of trust

The financial services industry has experienced rapid technological change [which] continues to encourage new ways of interacting with and serving customers. Such innovation creates important opportunities for banks of all sizes. When banks can be agile in developing relationships with third-party providers to meet unique customer needs, they can find their own paths to innovation. [Continue]

CECL: It’s Time (Again)

The pandemic has most likely sidetracked adoption and implementation plans and you may feel like you are back to square one. Given mass adoption is 14 months away, CECL fervor will pick up in the coming months. Before the CECL conversation goes mainstream, allow me to dispel a few CECL myths, offer insight gleaned from the more than 150 publicly traded banks that have already adopted the standard, and offer a sensible solution to consider for your CECL problem. [Continue]

Navigating the perils of Reg O

Most community bankers are familiar with Regulation O, the Federal Reserve’s set of rules intended to prevent abuse of bank credit by bank presidents, directors and other “insiders.” Reg O has been around for 40 years, and the terrain of compliance is well trodden. But familiarity doesn’t necessarily shield bankers and bank owners from the risks of running afoul of this key regulation. Its stipulations and restrictions are complicated, and pitfalls await those who fail to pay attention to the details. [Continue]

Preparing a response to a looming crisis

The banking industry is no stranger to crisis. From the Great Depression’s collapse of the financial system to the ag crisis of the 1980s to the housing crisis of 2008/2009… each era has brought about major — and permanent — changes to banking regulations. [Continue]

Cascading effects of climate change increasingly a Fed concern

Lael Brainard

Climate change is already imposing substantial economic costs and is projected to have a profound effect on the economy … and could have important implications for the Federal Reserve in carrying out its responsibilities. The Federal Reserve created a new Supervision Climate Committee to strengthen our capacity to identify and assess financial risks from climate change and to develop an appropriate program to ensure the resilience of our supervised firms to those risks. [Continue]

Faster, more comprehensive breach notification requirements proposed

The proposed rule would, among other things, require banks to notify their primary regulators of a triggering incident as soon as possible, and no later than 36 hours after learning that the incident occurred, and would require banking service providers to notify affected bank customers immediately after experiencing a security incident that disrupts or impairs services for four hours or more. The proposed rule would fundamentally change a bank’s current notification obligations. [Continue]

The year ahead: Privacy and cybersecurity issues

The financial services industry faced unprecedented cybersecurity and privacy challenges in 2020. From learning how to operate with a remote workforce to facing an exponential rise in the number and sophistication of cyberattacks, the resilience of financial institutions was tested to its limits. These challenges continue, yet 2021 brings a new set of challenges that are likely to substantially impact financial services companies in the year ahead. [Continue]

Today’s money laundering problem is bigger than we think

Most public comments and reporting following the FinCen leaks focused on whether the government will crack down on banks over money-laundering. But blaming banks misses a bigger point. Do our systems actually permanently put us in a position of playing catch up? Is the way we do automation today deeply flawed? I think it is. Automation actually needs machine learning or it can make problems it’s meant to fix worse. And maybe it’s more than most banks can take on at the same time after all. [Continue]

Carranza gets a big start at the SBA

September 30 marked the close of the 2020 fiscal year for the country; what an enormous year it turned out to be for the U.S. Small Business Administration. When Jovita Carranza was confirmed SBA Administrator in January, there was no way for her to know the agency was on the cusp of its biggest mission since the SBA was created in 1953: Help the country and its small businesses navigate a pandemic-induced recession.  [Continue]

The ABCs of managing effective regulatory exams

Compliance officers hold the proverbial ball when it comes to managing regulatory compliance examinations. Those who have experienced consistent, positive outcomes typically attribute their success to the fact they have a plan they stick to, year after year, to ensure there are no surprises and to portray their organization in the best possible light.  [Continue]