Financial Services · Regulation & Compliance
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24 articles · Financial Services · Regulation & Compliance · page 2 of 2
Articles
Week of 14 September 2020
Filing is not finding: FinCEN’s effectiveness question meets the FinCEN Files
In one September week, FinCEN asked what an effective anti-money laundering program really is, and leaked reports showed banks filing dutifully while flagged money kept moving. The gap between filing, usefulness and action was a data and decision problem that compliance metrics hid.
Week of 29 June 2020
Why Form CRS was the easy part of Regulation Best Interest
On June 30, 2020, brokers became bound to act in their retail customers’ best interest. Writing the plain-language summary, Form CRS, was the manageable part. Proving each recommendation met the standard, and that conflicts were controlled, took data most firms never captured.
Week of 25 May 2020
Why valid when made left bank-fintech lenders two open questions
The OCC’s May 29, 2020, rule said a national bank loan’s permissible interest survives its sale. That settled one big question for bank-fintech lending. Two harder ones remained: who is really the lender, and can the bank prove it is in charge?
Week of 2 March 2020
Why the FFIEC’s pandemic statement was an evidence checklist
On March 6, 2020, bank regulators restated pandemic expectations dating from the avian flu era. The statement’s real value lay in what examiners would later ask to see: staged decisions, critical work done with fewer people, and suppliers coping with the same disruption.