Bank Law Monitor
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FinCEN Reverses Course on Beneficial Ownership Requirements in Connection with Loan Renewals and Modifications
It can be hard for regulatory agencies to admit when they’ve made a mistake. But that’s exactly what FinCEN did last week when it announced that certain loan renewals and modifications[1] would not trigger its beneficial ownership due diligence rule...
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Reg CC Goes “Paperless”: New Amendments Address Electronic Checks, Remote Deposit Capture, and Other Modern Banking Trends
Regulation CC first became law back in 1992. Yes, that was when Sir Mix-a-Lot was “back” on the top of the charts, audiences were eating up Silence of the Lambs, and bowl cuts were a thing. Times have changed, but oddly Reg CC hasn’t. Since 1992, Reg...
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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...
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