On January 29, 2015, a state bank entered into a consent order with the Federal Deposit Insurance Corporation (“FDIC”), agreeing to pay a civil monetary penalty of $5,400 related to allegations that the bank had violated section 102(f)(1) of the Flood Disaster Protection Act of 1973, 42 U.S.C. § 4012a(f)(1),…
On January 15, 2015, the DOJ announced that it had entered a consent order in the U.S. District Court for the Northern District of Texas to resolve claims against a state-chartered bank based in Texas for allegedly discriminatory loan practices. The matter was referred to the DOJ by the FDIC,…
One of the most persistent and insidious threats to companies is cyber attacks. Whether these attacks involve theft of intellectual property, installation of malware, or denial of service, they pose a significant risk to businesses and their customers. For many companies, especially financial services companies, the risk is heightened by…
The Federal Reserve Board recently made headlines when it repealed its Regulation AA to comply with the Dodd-Frank Act, leading some to wonder how, and to what extent, regulation of financial institutions might change going forward. But the federal agencies charged with regulating banking and credit activities have made it clear that they will continue to enforce prohibitions…
On June 24, 2014, in response to the “increasing volume and sophistication of cyber threats,” the Federal Financial Institutions Examination Council (“FFIEC”) began a month-long cyber-security assessment of 500 community financial institutions and credit unions. Announcing what it dubbed a “pilot program,” the FFIEC—a formal, interagency body made up of…