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Water Under the Bridge: Revised Interagency Flood Insurance Q&As to Replace Decade-Old Q&As

For the first time in nearly a decade, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Farm Credit Administration, and the National Credit Union Administration (the Agencies) have proposed new, revised, and reorganized guidance on flood insurance (the Q&As). The Agencies published a first set of 118 proposed Q&As in July 2020, and a second set of 24 proposed Q&As relating to private insurance specifically on March 11, 2021. After the Q&As are consolidated into a single set and finalized, they ...

Legislative and Bank Regulatory Actions to Assist Forbearance in a Pandemic World

By Kristina Whittaker and Ed O'Keefe.  For the last three weeks or so, the federal and state banking agencies, collectively and individually, have, with increasing urgency, called on financial institutions to meet the financial needs of customers impacted by the COVID-19. Congress has now codified some of the guidance in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). To assist our clients in understanding the scale and scope of the regulatory actions, we describe the state of play as we know it today. 

As first discussed in the article by our colleagues Neil ...

COVID-19 National and State Relief Efforts Focus on Single Family Mortgage Loans

The shuttered storefronts and grounded airplanes that by now have become an all too familiar image of the COVID-19 pandemic are quickly creating a ripple effect through the U.S. economy. As unemployment rises and Americans struggle to pay their bills, federal and state governments and agencies are rushing to provide aid to those most impacted by the virus. A key focus of those efforts has been on mortgage related relief. This article canvasses the rapidly changing regulatory environment related to single family mortgage loans and provides an overview of the relief available to ...

Federal Reserve Discloses Plan for “FedNow” a Real Time Payment System

By Neil Bloomfield. The Federal Reserve Board (Federal Reserve) recently announced it will develop a “new round-the-clock real-time payment and settlement service”, named the FedNow℠Service to support faster payments in the United States.  FedNow will be a national instant payment system that is designed to offer an option for consumers and businesses to transfer up to $25,000 24x7x365. Federal Reserve Board Governor Lael Brainard stated, “FedNow will permit banks of every size in every community across the country to provide real-time payments to their customers.”

“At the Next Critical Stage in the Transition Away from LIBOR” – Federal Reserve Vice Chair Urges Companies, Financial Institutions to Begin Shift from LIBOR to Secured Overnight Financing Rate (SOFR)

 Noting that we are at “the start of the next critical stage in the transition away from LIBOR,” Federal Reserve Vice Chair for Supervision Randal K. Quarles delivered taped remarks at the June 3, 2019 Alternative Reference Rates Committee Roundtable, cohosted by the Alternative Reference Rates Committee and the New York University Stern School of Business and Salomon Center for the Study of Financial Institutions. Vice Chair Quarles reiterated warnings from regulators regarding the potential instability of LIBOR and stated that “[m]y key message to you today is that you ...

Bank Capital Plans and Stress Test Results Due April 5, 2019, CFTC Foreign Corrupt Practices Advisory on Self-Reporting/Cooperation

As government authorities around the world create a constantly evolving regulatory environment, conduct overlapping investigations, and bring parallel proceedings, companies are facing perhaps the most challenging regulatory and criminal enforcement environment. Our goal is to serve as a leading-edge resource for companies navigating these waters. Moore & Van Allen’s WCIRA News Clips is a complement to our White Collar Defense, Investigations, and Regulatory Advice Blog’s in-depth individual treatment of critical emerging issues. WCIRA News Clips hits the ...

New Federal Reserve Rating System; U.S. Sues UBS Over Residential Mortgage-Backed Securities; Traders Charged With Spoofing & More

As government authorities around the world create a constantly evolving regulatory environment, conduct overlapping investigations, and bring parallel proceedings, companies are facing perhaps the most challenging regulatory and criminal enforcement environment. Our goal is to serve as a leading-edge resource for companies navigating these waters. Moore & Van Allen’s WCIRA News Clips is a complement to our White Collar Defense, Investigations, and Regulatory Advice Blog’s in-depth individual treatment of critical emerging issues. WCIRA News Clips hits the ...

Bank Regulators Set Priorities at the Prudential Regulation Conference

Financial Regulatory Advice and Response Team members Neil Bloomfield, Ed O’Keefe, Tom Pennington, and Kris Whittaker attended the Prudential Regulation Conference presented by SIFMA and The Clearing House in Washington, D.C.  This year’s conference was focused on the future of prudential regulation, including the new leadership at the prudential agencies.  The conference included insights from the Joseph M. Otting, Comptroller of the Currency, Mark E. Van Der Weide, General Counsel for the Federal Reserve, and Jelena McWilliams, Chairman of the FDIC, among others.   There ...

About MVA White Collar Defense, Investigations, and Regulatory Advice Blog

As government authorities around the world conduct overlapping investigations and bring parallel proceedings in evolving regulatory environments, companies face challenging regulatory and criminal enforcement dynamics. We help keep our clients up to date in these fast-moving areas and to serve as a thought leader.

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