Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 31, 2024 Banking Dive article, “Did Regulators Send Warning Shot at Already Roiled BaaS Space?“
Pledging ‘Accountability,’ Biden’s FDIC Pick Faces Senate Test
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 10, 2024 Law360 article, “Pledging ‘Accountability,’ Biden’s FDIC Pick Faces Senate Test.”
“She’s going to get lots of questions about her banking experience, her bank regulatory experience and her leadership and management experience,” said Alexandra Steinberg Barrage, a
What Is the Cost of Doing Banking as a Service ‘Well’?
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 26, 2024 American Banker article, “What Is the Cost of Doing Banking as a Service ‘Well’?”
“In my experience, there is always some tweaking,” said Alexandra Barrage, a partner at Troutman Pepper.
Leaders across the bank – from
Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships
Yesterday, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting potential risks associated with banks’ arrangements with third parties to deliver bank deposit products and services. While the information is not new, it clearly memorializes the issues that have been at the forefront of recent enforcement actions involving banks operating under a Banking-as-a-Service (BaaS) model.
Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking
As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements for financial institutions subject to the Bank Secrecy Act (BSA). Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement announcing their own notice of proposed rulemaking for their supervised institutions. The purpose of the proposed rulemaking is to align the agencies’ respective AML/CFT program rules with FinCEN’s proposed revisions, ensuring a unified standard for compliance.
Hsu Signals OCC to Review Preemption Rules
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 18, 2024 Banking Dive article, “Hsu Signals OCC to Review Preemption Rules.”
Hsu’s comments suggest the OCC’s preemption rules following Dodd-Frank can’t really be relied on anymore, said Alexandra Steinberg Barrage, a partner at law firm Troutman Pepper
Loper Bright and Cantero Are Ushering in a New Era of Preemption
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was quoted in the July 18, 2024 American Banker article, “Loper Bright and Cantero Are Ushering in a New Era of Preemption.”
“If I’m a national bank, I’m going to rethink my reliance on those preemption rules, given what the Supreme Court has
Regulation for Banking Institutions
Alexandra Barrage, a partner in Troutman Pepper’s Corporate Practice Group, was interviewed in the July 15, 2024 segment of Bloomberg: The Close, “Regulation for Banking Institutions.”
FinCEN Proposes Rule to Strengthen AML/CFT Programs
On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the financing of terrorism (AML/CFT) programs. The Treasury’s priority is to promote a more effective risk-based regulatory regime that directs financial institutions to focus their AML/CFT programs on the highest priority threats.
OCC Proposes Amendments to its Recovery Planning Guidelines
On June 24, the Office of the Comptroller of the Currency (OCC) announced it is requesting comments on proposed amendments to its recovery planning guidelines. A recovery plan’s purpose is to provide a covered bank with a framework to effectively and efficiently address the financial effects of severe stress events and avoid failure or resolution. Among other things, the proposed amendments aim to expand the guidelines to apply to banks with average total consolidated assets between $100 billion and $250 billion. The proposal also seeks to incorporate a testing standard and clarify the role of non-financial risks in recovery planning.