Insights

The latest in financial regulation, explained by Patomak’s team of former regulators and senior-level industry experts.

OCC Expands Recovery Planning Requirements

Banking & Consumer Finance Heather Espinosa

Summary: Situation Overview: The Office of the Comptroller of the Currency (OCC) finalized revisions to Recovery Planning Guidelines, which substantively change the scope and expectations for recovery plans. What: The OCC is increasingly focusing…

OCC Expands Recovery Planning Requirements

Banking & Consumer Finance Heather Espinosa

Summary: Situation Overview: The Office of the Comptroller of the Currency (OCC) finalized revisions to Recovery Planning Guidelines, which substantively change the scope and expectations for recovery plans. What: The OCC is increasingly focusing…

OCC Expands Recovery Planning Requirements

Banking & Consumer Finance Heather Espinosa

Summary: Situation Overview: The Office of the Comptroller of the Currency (OCC) finalized revisions to Recovery Planning Guidelines, which substantively change the scope and expectations for recovery plans. What: The OCC is increasingly focusing…

Securities

Navigating the SEC Approval Process: Key Strategies for Ethereum ETP Applicants

Digital Assets, Securities Priscilla Carias, Anika Horowitz, Laura Magyar, Mark Wetjen

SEC Adopts Exchange Act Rules 3a5-4 and 3a44-2 – Dealer Registration Requirements

Securities Wilson Friestad, Laura Magyar

SEC Security-Based Swap Dealer Exam Observations Focus on Trade Reporting and Other Areas

Securities Anne Montminy, Carly Ritterband

AML Compliance Continues to be an SEC Priority

AML, Sanctions & CFIUS, Securities Wilson Friestad, Drew Godsell, Laura Magyar, John Vivian

SEC Adopts New Cybersecurity Disclosure Requirements for Public Companies

Securities Bob Phelps, Kathy Casey, Laura Magyar, Stephanie Moore, Hemal Patwa

SEC Set to Finalize Rules on Outsourcing by Registered Investment Advisers and Potentially Move Further Into Internet-Based RIA Ecosystem

Securities Carly Ritterband, Mark Wetjen

SEC Increases Oversight of Registered Investment Advisers

Securities Laura Magyar, Tim Tian

SEC Adopts Additional Disclosure Requirements for Private Funds

Securities Adam Glazer

The Curious Case of the Hidden FAQ

Securities Adam Glazer

Navigating the SEC Approval Process: Key Strategies for Ethereum ETP Applicants

Digital Assets, Securities Priscilla Carias, Anika Horowitz, Laura Magyar, Mark Wetjen

SEC Adopts Exchange Act Rules 3a5-4 and 3a44-2 – Dealer Registration Requirements

Securities Wilson Friestad, Laura Magyar

SEC Security-Based Swap Dealer Exam Observations Focus on Trade Reporting and Other Areas

Securities Anne Montminy, Carly Ritterband

AML Compliance Continues to be an SEC Priority

AML, Sanctions & CFIUS, Securities Wilson Friestad, Drew Godsell, Laura Magyar, John Vivian

SEC Adopts New Cybersecurity Disclosure Requirements for Public Companies

Securities Bob Phelps, Kathy Casey, Laura Magyar, Stephanie Moore, Hemal Patwa

SEC Set to Finalize Rules on Outsourcing by Registered Investment Advisers and Potentially Move Further Into Internet-Based RIA Ecosystem

Securities Carly Ritterband, Mark Wetjen

SEC Increases Oversight of Registered Investment Advisers

Securities Laura Magyar, Tim Tian

SEC Adopts Additional Disclosure Requirements for Private Funds

Securities Adam Glazer

The Curious Case of the Hidden FAQ

Securities Adam Glazer

Navigating the SEC Approval Process: Key Strategies for Ethereum ETP Applicants

Digital Assets, Securities Priscilla Carias, Anika Horowitz, Laura Magyar, Mark Wetjen

SEC Adopts Exchange Act Rules 3a5-4 and 3a44-2 – Dealer Registration Requirements

Securities Wilson Friestad, Laura Magyar

SEC Security-Based Swap Dealer Exam Observations Focus on Trade Reporting and Other Areas

Securities Anne Montminy, Carly Ritterband

AML Compliance Continues to be an SEC Priority

AML, Sanctions & CFIUS, Securities Wilson Friestad, Drew Godsell, Laura Magyar, John Vivian

SEC Adopts New Cybersecurity Disclosure Requirements for Public Companies

Securities Bob Phelps, Kathy Casey, Laura Magyar, Stephanie Moore, Hemal Patwa

SEC Set to Finalize Rules on Outsourcing by Registered Investment Advisers and Potentially Move Further Into Internet-Based RIA Ecosystem

Securities Carly Ritterband, Mark Wetjen

SEC Increases Oversight of Registered Investment Advisers

Securities Laura Magyar, Tim Tian

SEC Adopts Additional Disclosure Requirements for Private Funds

Securities Adam Glazer

The Curious Case of the Hidden FAQ

Securities Adam Glazer

Derivatives

CFTC Enforcement Takes Aim at Position Limit Violations

Derivatives Robert Lulgjuraj, Tim Brown Risk Management & Compliance

IMX Health: The First CFTC-Approved Healthcare Derivatives Market

Derivatives Isabelle Allesi, Jill Sommers

NFA Highlights Common Compliance Deficiencies for Swap Dealer Members

Derivatives Leon Kamenev, Tim Brown, Sudhir Jain, Joshua Kuntz

CFTC Seeks Comments on AI Usage and Risks in Derivatives Markets

Derivatives Wilson Friestad, Sudhir Jain

CFTC Proposes Amendments to Reporting Requirements Including a 37% Increase in the Number of Reportable Fields

Derivatives Anne Montminy, Tim Brown, Sudhir Jain, Jill Sommers, Mark Wetjen

Digital Assets, Market Integrity, and Market Transparency Highlight the CFTC’s Enforcement Focus from FY2023

Derivatives, Digital Assets Tim Brown, Sudhir Jain, Cole Reynolds

Firms Need to Weigh in on CFTC Notice of Proposed Rulemaking for Risk Management Requirements

Derivatives Tim Brown, Sudhir Jain, Joshua Kuntz

CFTC Reminds Non-U.S. Swap Dealers of Annual Report Requirements in Newly Issued Advisory

Derivatives Anika Horowitz, Sudhir Jain

Swap Dealers Face Further Enforcement Orders in 2022

Derivatives Sudhir Jain, Jamila Piracci, Jill Sommers

CFTC Enforcement Takes Aim at Position Limit Violations

Derivatives Robert Lulgjuraj, Tim Brown Risk Management & Compliance

IMX Health: The First CFTC-Approved Healthcare Derivatives Market

Derivatives Isabelle Allesi, Jill Sommers

NFA Highlights Common Compliance Deficiencies for Swap Dealer Members

Derivatives Leon Kamenev, Tim Brown, Sudhir Jain, Joshua Kuntz

CFTC Seeks Comments on AI Usage and Risks in Derivatives Markets

Derivatives Wilson Friestad, Sudhir Jain

CFTC Proposes Amendments to Reporting Requirements Including a 37% Increase in the Number of Reportable Fields

Derivatives Anne Montminy, Tim Brown, Sudhir Jain, Jill Sommers, Mark Wetjen

Digital Assets, Market Integrity, and Market Transparency Highlight the CFTC’s Enforcement Focus from FY2023

Derivatives, Digital Assets Tim Brown, Sudhir Jain, Cole Reynolds

Firms Need to Weigh in on CFTC Notice of Proposed Rulemaking for Risk Management Requirements

Derivatives Tim Brown, Sudhir Jain, Joshua Kuntz

CFTC Reminds Non-U.S. Swap Dealers of Annual Report Requirements in Newly Issued Advisory

Derivatives Anika Horowitz, Sudhir Jain

Swap Dealers Face Further Enforcement Orders in 2022

Derivatives Sudhir Jain, Jamila Piracci, Jill Sommers

CFTC Enforcement Takes Aim at Position Limit Violations

Derivatives Robert Lulgjuraj, Tim Brown Risk Management & Compliance

IMX Health: The First CFTC-Approved Healthcare Derivatives Market

Derivatives Isabelle Allesi, Jill Sommers

NFA Highlights Common Compliance Deficiencies for Swap Dealer Members

Derivatives Leon Kamenev, Tim Brown, Sudhir Jain, Joshua Kuntz

CFTC Seeks Comments on AI Usage and Risks in Derivatives Markets

Derivatives Wilson Friestad, Sudhir Jain

CFTC Proposes Amendments to Reporting Requirements Including a 37% Increase in the Number of Reportable Fields

Derivatives Anne Montminy, Tim Brown, Sudhir Jain, Jill Sommers, Mark Wetjen

Digital Assets, Market Integrity, and Market Transparency Highlight the CFTC’s Enforcement Focus from FY2023

Derivatives, Digital Assets Tim Brown, Sudhir Jain, Cole Reynolds

Firms Need to Weigh in on CFTC Notice of Proposed Rulemaking for Risk Management Requirements

Derivatives Tim Brown, Sudhir Jain, Joshua Kuntz

CFTC Reminds Non-U.S. Swap Dealers of Annual Report Requirements in Newly Issued Advisory

Derivatives Anika Horowitz, Sudhir Jain

Swap Dealers Face Further Enforcement Orders in 2022

Derivatives Sudhir Jain, Jamila Piracci, Jill Sommers

Banking & Consumer Finance

OCC Expands Recovery Planning Requirements

Banking & Consumer Finance Heather Espinosa

Mortgage Market at a Crossroads: Confronting Rising Costs & Supply Challenges

Banking & Consumer Finance Jason Cave

FDIC and OCC Focus on Resolution and Recovery Capabilities Testing

Banking & Consumer Finance Diane Daley, Mona Elliot, Heather Espinosa

Examining the New Debate on CFPB Funding

Banking & Consumer Finance Brian Johnson

Stress Test Results Keep Risk Management Capabilities in Focus

Banking & Consumer Finance Diane Daley, Mona Elliot, Heather Espinosa

FHFA RFI Makes Housing and Community Development Mission Achievement a Priority for FHLBanks

Banking & Consumer Finance Jason Cave, Heather Espinosa, Stephanie Moore

What is the Future of Basel III Endgame?

Banking & Consumer Finance Anika Horowitz, Jill Sommers

CFPB and OCC Increase Focus on “Buy Now, Pay Later” (BNPL) Lending

Banking & Consumer Finance Anika Horowitz, Brian Johnson, John Vivian

OCC Proposes New Guidelines for Bank Mergers

Banking & Consumer Finance Katherine McCarthy, Keith Noreika, Carly Ritterband, John Vivian

OCC Expands Recovery Planning Requirements

Banking & Consumer Finance Heather Espinosa

Mortgage Market at a Crossroads: Confronting Rising Costs & Supply Challenges

Banking & Consumer Finance Jason Cave

FDIC and OCC Focus on Resolution and Recovery Capabilities Testing

Banking & Consumer Finance Diane Daley, Mona Elliot, Heather Espinosa

Examining the New Debate on CFPB Funding

Banking & Consumer Finance Brian Johnson

Stress Test Results Keep Risk Management Capabilities in Focus

Banking & Consumer Finance Diane Daley, Mona Elliot, Heather Espinosa

FHFA RFI Makes Housing and Community Development Mission Achievement a Priority for FHLBanks

Banking & Consumer Finance Jason Cave, Heather Espinosa, Stephanie Moore

What is the Future of Basel III Endgame?

Banking & Consumer Finance Anika Horowitz, Jill Sommers

CFPB and OCC Increase Focus on “Buy Now, Pay Later” (BNPL) Lending

Banking & Consumer Finance Anika Horowitz, Brian Johnson, John Vivian

OCC Proposes New Guidelines for Bank Mergers

Banking & Consumer Finance Katherine McCarthy, Keith Noreika, Carly Ritterband, John Vivian

OCC Expands Recovery Planning Requirements

Banking & Consumer Finance Heather Espinosa

Mortgage Market at a Crossroads: Confronting Rising Costs & Supply Challenges

Banking & Consumer Finance Jason Cave

FDIC and OCC Focus on Resolution and Recovery Capabilities Testing

Banking & Consumer Finance Diane Daley, Mona Elliot, Heather Espinosa

Examining the New Debate on CFPB Funding

Banking & Consumer Finance Brian Johnson

Stress Test Results Keep Risk Management Capabilities in Focus

Banking & Consumer Finance Diane Daley, Mona Elliot, Heather Espinosa

FHFA RFI Makes Housing and Community Development Mission Achievement a Priority for FHLBanks

Banking & Consumer Finance Jason Cave, Heather Espinosa, Stephanie Moore

What is the Future of Basel III Endgame?

Banking & Consumer Finance Anika Horowitz, Jill Sommers

CFPB and OCC Increase Focus on “Buy Now, Pay Later” (BNPL) Lending

Banking & Consumer Finance Anika Horowitz, Brian Johnson, John Vivian

OCC Proposes New Guidelines for Bank Mergers

Banking & Consumer Finance Katherine McCarthy, Keith Noreika, Carly Ritterband, John Vivian

Digital Assets

Navigating the SEC Approval Process: Key Strategies for Ethereum ETP Applicants

Digital Assets, Securities Priscilla Carias, Anika Horowitz, Laura Magyar, Mark Wetjen

Digital Assets, Market Integrity, and Market Transparency Highlight the CFTC’s Enforcement Focus from FY2023

Derivatives, Digital Assets Tim Brown, Sudhir Jain, Cole Reynolds

Effects of Proposed FSOC Guidance

Banking & Consumer Finance, Digital Assets Paul Atkins, Robert Greene, Keith Noreika, Jill Sommers

Federal Reserve Hardens Stance Towards Crypto, Denies Bank Membership

Banking & Consumer Finance, Digital Assets Chris Beckmann, Bryan Hubbard, Keith Noreika

Crypto Requires Robust Risk Management Framework

Digital Assets Sudhir Jain, Joshua Kuntz

FSOC Releases Digital Asset Report, Signaling Increased Future Scrutiny

Digital Assets Chris Beckmann, Robert Greene, Brian Johnson

Our Op-Ed in the American Banker: An Unworkable Compromise on Stablecoins

Banking & Consumer Finance, Digital Assets, News Paul Atkins

Federal Reserve Board Announces Updated Guidelines for Account Access, But Questions Remain

Banking & Consumer Finance, Digital Assets Chris Beckmann, Keith Noreika

Senators Pressure OCC to Rescind Crypto Bank Guidance, Adding Regulatory Uncertainty

Banking & Consumer Finance, Digital Assets, Patomak Post Chris Beckmann, Keith Noreika

Navigating the SEC Approval Process: Key Strategies for Ethereum ETP Applicants

Digital Assets, Securities Priscilla Carias, Anika Horowitz, Laura Magyar, Mark Wetjen

Digital Assets, Market Integrity, and Market Transparency Highlight the CFTC’s Enforcement Focus from FY2023

Derivatives, Digital Assets Tim Brown, Sudhir Jain, Cole Reynolds

Effects of Proposed FSOC Guidance

Banking & Consumer Finance, Digital Assets Paul Atkins, Robert Greene, Keith Noreika, Jill Sommers

Federal Reserve Hardens Stance Towards Crypto, Denies Bank Membership

Banking & Consumer Finance, Digital Assets Chris Beckmann, Bryan Hubbard, Keith Noreika

Crypto Requires Robust Risk Management Framework

Digital Assets Sudhir Jain, Joshua Kuntz

FSOC Releases Digital Asset Report, Signaling Increased Future Scrutiny

Digital Assets Chris Beckmann, Robert Greene, Brian Johnson

Our Op-Ed in the American Banker: An Unworkable Compromise on Stablecoins

Banking & Consumer Finance, Digital Assets, News Paul Atkins

Federal Reserve Board Announces Updated Guidelines for Account Access, But Questions Remain

Banking & Consumer Finance, Digital Assets Chris Beckmann, Keith Noreika

Senators Pressure OCC to Rescind Crypto Bank Guidance, Adding Regulatory Uncertainty

Banking & Consumer Finance, Digital Assets, Patomak Post Chris Beckmann, Keith Noreika

Navigating the SEC Approval Process: Key Strategies for Ethereum ETP Applicants

Digital Assets, Securities Priscilla Carias, Anika Horowitz, Laura Magyar, Mark Wetjen

Digital Assets, Market Integrity, and Market Transparency Highlight the CFTC’s Enforcement Focus from FY2023

Derivatives, Digital Assets Tim Brown, Sudhir Jain, Cole Reynolds

Effects of Proposed FSOC Guidance

Banking & Consumer Finance, Digital Assets Paul Atkins, Robert Greene, Keith Noreika, Jill Sommers

Federal Reserve Hardens Stance Towards Crypto, Denies Bank Membership

Banking & Consumer Finance, Digital Assets Chris Beckmann, Bryan Hubbard, Keith Noreika

Crypto Requires Robust Risk Management Framework

Digital Assets Sudhir Jain, Joshua Kuntz

FSOC Releases Digital Asset Report, Signaling Increased Future Scrutiny

Digital Assets Chris Beckmann, Robert Greene, Brian Johnson

Our Op-Ed in the American Banker: An Unworkable Compromise on Stablecoins

Banking & Consumer Finance, Digital Assets, News Paul Atkins

Federal Reserve Board Announces Updated Guidelines for Account Access, But Questions Remain

Banking & Consumer Finance, Digital Assets Chris Beckmann, Keith Noreika

Senators Pressure OCC to Rescind Crypto Bank Guidance, Adding Regulatory Uncertainty

Banking & Consumer Finance, Digital Assets, Patomak Post Chris Beckmann, Keith Noreika

AML, Sanctions & CFIUS

Treasury Department

Treasury Issues Notice of Proposed Rulemaking Implementing the White House’s Executive Order on Outbound Investment

AML, Sanctions & CFIUS Thomas Feddo, Robert Greene

AML Compliance Continues to be an SEC Priority

AML, Sanctions & CFIUS, Securities Wilson Friestad, Drew Godsell, Laura Magyar, John Vivian

President Biden’s Outbound Investment Executive Order: New Investment Prohibition and Notification Requirements Remains Far from Certain

AML, Sanctions & CFIUS Thomas Feddo, Robert Greene

FinCEN Assesses Civil Money Penalty Against First Trust Company for BSA Violations

AML, Sanctions & CFIUS Stephanie Moore, Keith Noreika, Suzanne Richards, Cynthia Shea

Carnegie Endowment for International Peace: Beijing’s Global Ambitions for Central Bank Digital Currencies Are Growing Clearer

AML, Sanctions & CFIUS Robert Greene

Conglomeration Unbound: The Origins and Globally Unparalleled Structures of Multi-sector Chinese Corporate Groups Controlling Large Financial Companies

AML, Sanctions & CFIUS Robert Greene

What Will Be the Impact of China’s State-Sponsored Digital Currency?

AML, Sanctions & CFIUS, Digital Assets Robert Greene

Treasury Department

Treasury Issues Notice of Proposed Rulemaking Implementing the White House’s Executive Order on Outbound Investment

AML, Sanctions & CFIUS Thomas Feddo, Robert Greene

AML Compliance Continues to be an SEC Priority

AML, Sanctions & CFIUS, Securities Wilson Friestad, Drew Godsell, Laura Magyar, John Vivian

President Biden’s Outbound Investment Executive Order: New Investment Prohibition and Notification Requirements Remains Far from Certain

AML, Sanctions & CFIUS Thomas Feddo, Robert Greene

FinCEN Assesses Civil Money Penalty Against First Trust Company for BSA Violations

AML, Sanctions & CFIUS Stephanie Moore, Keith Noreika, Suzanne Richards, Cynthia Shea

Carnegie Endowment for International Peace: Beijing’s Global Ambitions for Central Bank Digital Currencies Are Growing Clearer

AML, Sanctions & CFIUS Robert Greene

Conglomeration Unbound: The Origins and Globally Unparalleled Structures of Multi-sector Chinese Corporate Groups Controlling Large Financial Companies

AML, Sanctions & CFIUS Robert Greene

What Will Be the Impact of China’s State-Sponsored Digital Currency?

AML, Sanctions & CFIUS, Digital Assets Robert Greene

Treasury Department

Treasury Issues Notice of Proposed Rulemaking Implementing the White House’s Executive Order on Outbound Investment

AML, Sanctions & CFIUS Thomas Feddo, Robert Greene

AML Compliance Continues to be an SEC Priority

AML, Sanctions & CFIUS, Securities Wilson Friestad, Drew Godsell, Laura Magyar, John Vivian

President Biden’s Outbound Investment Executive Order: New Investment Prohibition and Notification Requirements Remains Far from Certain

AML, Sanctions & CFIUS Thomas Feddo, Robert Greene

FinCEN Assesses Civil Money Penalty Against First Trust Company for BSA Violations

AML, Sanctions & CFIUS Stephanie Moore, Keith Noreika, Suzanne Richards, Cynthia Shea

Carnegie Endowment for International Peace: Beijing’s Global Ambitions for Central Bank Digital Currencies Are Growing Clearer

AML, Sanctions & CFIUS Robert Greene

Conglomeration Unbound: The Origins and Globally Unparalleled Structures of Multi-sector Chinese Corporate Groups Controlling Large Financial Companies

AML, Sanctions & CFIUS Robert Greene

What Will Be the Impact of China’s State-Sponsored Digital Currency?

AML, Sanctions & CFIUS, Digital Assets Robert Greene

News

Robert Greene Quoted in Foreign Policy

News Robert Greene

Laura Magyar at NSCP Conference

Panel Discussion Featuring Paul Atkins

News Paul Atkins

Kathy Casey Joins CAQ Governing Board

Keith Noreika Quoted in Semafor

News Keith Noreika

Keith Noreika Quoted in American Banker

News Keith Noreika

Op-Ed: Regulators Must Get the Central Hub of the Market Ecosystem Right

News Paul Atkins, Jill Sommers

Jason Cave Quoted on Bank Fintech Partnerships in S&P Global

News Patomak Global Partners