Public companies should note a recent settlement with the US Securities and Exchange Commission (“SEC”). On March 9, 2023, the SEC announced that Blackbaud Inc. agreed to pay $3 million to settle charges for alleged misleading disclosures about its 2020 ransomware attack and for alleged disclosure control failures. This serves as a reminder for public
Jeffrey P. Taft
Virtual Currency Activity Prior Approval Requirement Established by NYDFS
Posted in Fintech, Regulatory
On December 15, 2022, the New York Department of Financial Services (“NYDFS”) issued guidance clarifying that all New York banking organizations are required to obtain prior agency approval for virtual currency-related activity (“2022 Guidance”). The 2022 Guidance is similar to prior notice guidance issued by the federal banking regulators but establishes highly prescriptive information requirements…
Legal Update: Proposed Revisions to Volcker Rule Covered Funds Provisions
On January 30, 2020, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Securities and Exchange Commission, and the Commodity Futures Trading Commission proposed revisions to the covered funds provisions of the Volcker Rule. The proposal is intended to address the…
Legal Update: Volcker Rule Revisions Adopted by Agencies
By David R. Sahr, Donald S. Waack, Anna T. Pinedo, Carol A. Hitselberger, Jeffrey P. Taft, Thomas J. Delaney, Marla Matusic & Matthew Bisanz on
Posted in Volcker Rule
The US federal banking and functional regulators (“Agencies”) have finalized revisions to the proprietary trading and compliance program provisions of the Volcker Rule, which implement some, though not all, of the changes that had been proposed by the Agencies in a May 2018 notice of proposed rulemaking. This Legal Update discusses the revisions.