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Category: Compliance

New PPP Compliance Procedures for 2021

The government delegated approval authority to lenders for the first round of Paycheck Protection Program loans in 2020—reflecting the emergency […]

Recent FinCEN Guidance Highlights Importance of Policies, Procedures, and Processes

Recently, FinCEN issued guidance regarding seven FAQs related to Suspicious Activity Reporting (SAR) filing requirements and “Keep Open” Requests, with […]

New Cybersecurity Rulemaking Proposed for Banking Industry

On January 12, 2021, financial regulators jointly published a new notice of proposed cybersecurity rulemaking for the banking industry. See […]

Banking-as-a-Service and How Traditional Banks are Adapting

Banks have always adapted to emerging technologies and market behavior. Consider the changes to bank products, services, and pricing over […]

SEC Amendments to Private Offering Framework

Publicly traded companies raise capital by selling their securities on national exchanges. The public offerings are registered with the Securities […]

PPP Loan Enforcement Begins With SBA Issuing a Borrower Questionnaire

The Small Business Administration will soon require borrowers who received Paycheck Protection Program loans greater than $2 million to complete […]

Avoiding FCPA Trouble – Hints from the DOJ’s Advisory Opinion

If you conduct business internationally, pay attention. A recent Department of Justice advisory opinion offers guidance in complying with the […]

OCC’s New “True Lender” Rule Already Having Positive Effects: Colorado Settles Long-Running “True Lender” Case

The Office of the Comptroller of Currency recently issued a proposed Final Rule concerning when a national bank is the […]