Bank Law Monitor
All Articles
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...
Continue Reading >
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...
Continue Reading >
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...
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 >