All Articles
Non-Payee Indorsement Triggers One-Year Limitations Period, Washington Supreme Court Holds
Banks have long been a favorite target for lawsuits when their customers don’t take basic steps to oversee their employees who later bilk the customer for millions of dollars over the course of untold years. Customers often try to hold the bank liabl...
Continue Reading >
The SEC’s New Pay Ratio Rule
The Securities and Exchange Commission (SEC) recently adopted a new executive compensation disclosure requirement which will require comparison of the compensation of a company’s CEO to that of a “median employee” of the company.
The pay ratio rule...
Continue Reading >
Monday Morning Quarterbacking
Back to the Future
As I prepare for a presentation at the WIB Annual Directors Conference, it strikes me that it has been seven years since the financial meltdown. While our economy has improved, it still has not completely recovered and the Fed and...
Continue Reading >
Confluence
Deal Talk
Well, it’s almost Spring and the flowers and deal talk are starting to bloom. We hear and see a lot of activity going on in the Western United States. Our sense is that this activity is being fueled by a confluence of factors: continuing lo...
Continue Reading >
CFPB Finds “Deceptive” Data Security Practices Without Consumer Harm and Requires Dwolla to Implement a Written Data Security Plan
On February 16, 2016, the Consumer Financial Protection Bureau (CFPB) issued a Consent Order relating to certain “deceptive” acts and practices of Dwolla, Inc., an Iowa based payment processor (Dwolla). Dwolla operates a software platform that enable...
Continue Reading >
Coping with the CAMELS
Introduction
In connection with a presentation I was asked to make by the Federal Home Loan Bank to some of its member banks, I crafted this article on “Coping with the CAMELS.” As you know, this is an acronym for the six ratings in commercial bank e...
Continue Reading >