Bank Law Monitor
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Article 12 – Perfection of Security Interests in Controllable Electronic Records
It is well established how to perfect a security interest on general intangibles under Article 9 of the Uniform Commercial Code: filing a financing statement. But is there a better way for a secured party who wants to stay in first position on assets...
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New Reporting Requirements for Deposit Interest Paid to Residents of Chile
On September 28, 2021, the IRS released an advance version of Revenue Procedure 2021-32, updating previous guidance with respect to information reporting requirements applicable to residents of certain countries. Under previous guidance, the United S...
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SEC Adopts New Amendments to Exempt Offering Rules
The Securities and Exchange Commission (SEC) has adopted a series of amendments to rules under the Securities Act of 1933 (Securities Act) applicable to offerings exempt from public registration. The amendments will become effective 60 days after the...
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Banking Regulators Encourage Lenders to Work with Borrowers Impacted by COVID-19
Mar 23, 2020
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Federal banking regulators took a bold, first step this past Sunday, announcing Interagency Guidance ("the Guidance") to encourage lenders to work with borrowers impacted by the COVID-19 outbreak.[1] The Guidance specifically permits lenders to enter...
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DOJ Rescinds the Cole Memo—What It Means for Your Financial Institution
Reiterating that Congress considers marijuana to be a "dangerous drug" and marijuana activity to be a "serious crime," Attorney General Jeff Sessions today issued a memo to all U.S. attorneys rescinding various memoranda related to enforcem...
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Update: DOJ Rescinds the Cole Memo—FinCen Guidance Still in Effect, For Now…
In the wake of the shift in federal marijuana enforcement policy, financial institutions have been left to speculate the risk in offering financial services to marijuana-related businesses. While the U.S. Treasury Department's Financial Crimes Enforc...
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