Proposed Legislation Would Require Financial Institutions To Report Data For Accounts With Annual Activity Of $600

In May 2021, as part of the American Families Plan, the Biden Administration proposed that financial institutions should report consumer and business account activity exceeding $600 annually. Proponents of the legislation claim that it will give the Internal Revenue Service (“IRS”) additional information to assist with audits while the proposed legislation has raised compliance and privacy concerns from critics.

The proposed American Families Plan legislation would require that financial institutions report transaction data for any […]

By | September 7th, 2021 ||

CFTC Staff Provides Temporary Financial Reporting Relief To Bank Swap Dealers

CFTC staff provided temporary no-action relief to swap dealers subject to the capital requirements of prudential regulators (“Bank SDs”) from the CFTC’s swap dealer financial reporting rules.

CFTC Letter 21-18, which was issued in response to a SIFMA and ISDA joint request, provides relief from certain financial reporting requirements under CFTC Rule 23.105(p)(2) (“Financial Report and Position Information”) and information otherwise required to be submitted on CFTC Appendix C to Subpart E of Part 23.

The CFTC stated that it will not […]

By | September 3rd, 2021 ||

Federal Reserve Proposes Guidelines For Access To Federal Reserve Bank Services For Non-Traditional Federal And State Charters

The Board of Governors of the Federal Reserve System (“FRS”) has proposed guidelines that the regional Federal Reserve Banks (“FRBs”) would use to evaluate requests for accounts and payment services (the “Proposed Guidelines”).1 As discussed in Operating Circular No. 1, an institution has the option to settle its FRB services transactions in its master account with an FRB or in the master account of another institution that has agreed to act as its correspondent. The […]

By | September 2nd, 2021 ||