#OFAC – Page 2 – Federal Financial Analytics

14 06, 2022

FedFin On: U.S. Digital-Asset Framework

Arezou Rafikian2023-01-27T15:30:30-05:00June 14th, 2022|The Vault|

After protracted negotiations and much public attention, bipartisan senators have introduced a far-reaching bill designed to encourage digital-asset use without undue risk to consumers, investors, or the financial system. The bill decides most, if not all, of the outstanding regulatory barriers to digital-asset use in favor of digital assets and their providers. Provisions in many cases go farther than public discussion has so far noted – for example, the measure not only expands the ability of digital-asset providers to reach retail and wholesale customers, but also gives them access to FDIC resolution without the cost of paying insurance premiums or coming under many of the rules that govern insured depositories…

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…

9 05, 2022

DAILY050922

Eliza Allen2023-03-01T13:21:36-05:00May 9th, 2022|2- Daily Briefing|

U.S. Adopts Powerful Back-Door Campaign vs. Shell Companies, Trusts

In conjunction with a G-7 statement strongly condemning Russia, Treasury took an innovative move to address shell companies linked to the Russian Federation even as FinCEN’s beneficial-ownership rules remain bogged down.

Hsu Promises Deal-By-Deal Review of Large Regional M&A Pending Broad, Forward-Looking Policy

Citing changes in both U.S. banking and inequality since the last round of merger-policy statements in 1995, Acting Comptroller Hsu today called for a new policy that is neither pro- nor anti-merger but rather determines which larger mergers are “good” transactions so that only risky ones are rejected.

SEC Bows to Critics with Longer Comment Periods

In a significant concession to Congressional Republicans and industry critics, the SEC today extended the comment period for two of its most controversial initiatives. The deadline for comments on its climate-risk disclosures is moved forward by twenty-eight days to June 17.

CFPB Takes Administrative Action Expanding ECOA Reach, Lender Risk

Living up to its promise on Friday to address structural racism, the CFPB today issued a new advisory extending its fair-lending enforcement scope under the ECOA to all aspects of a credit transaction, not just loan origination or servicing.

Daily050922.pdf…

31 03, 2022

DAILY033122

Eliza Allen2023-03-27T14:51:11-04:00March 31st, 2022|2- Daily Briefing|

FSB Stays Its Course

The FSB today officially published its 2022 work plan, making only one change in terms of topics and timing from the plan detailed in a February letter to G20 finance ministers and central bankers.

HFSC Democrats Don’t Like Overdrafts, But No Action Imminent

As anticipated, today’s HFSC Consumer Protection Subcommittee hearing reviewed Democratic complaints about overdraft fees and a general Republican defense of the importance of the private sector in setting consumer-finance charges.

Sanctions Now Reach Sectors

Treasury’s OFAC today sharply expanded U.S. sanctions against the Russian Federation.

Gensler Tackles Climate Disclosures, Crypto

Noting that the SEC is focused on disclosures, not the “merit” of what issuers may do, SEC Chairman Gensler today defended the controversial Scope 3 climate-risk disclosures, calling them “layered” because mandatory upstream and downstream disclosures would only be required if exposures are material or if a company had made a risk-reduction commitment.

GOP Bill Would Ban CBDC

Clearly still laying out the CBDC political divide, Sens. Cruz (R-TX), Braun (R-IN), and Grassley (R-IA) have introduced S. 3954, legislation essentially barring a retail-focused CBDC if it serves – as the senators expect – as a “financial surveillance tool.”

Thompson Open to FHLB Inquiry, New Mortgage Product

In the wake of another op-ed questioning the purpose of the home loan bank system, acting FHFA director Thompson said today that the creation of an advisory committee to review the system is a “great idea” to which she is open, saying also …

2 03, 2022

DAILY030222

Eliza Allen2023-04-04T12:58:20-04:00March 2nd, 2022|2- Daily Briefing|

Senate Banking Tackles Crypto Sanctions Compliance

Reflecting ongoing developments, Senate Banking Chairman Brown (D-OH) and several of his Democratic colleagues today wrote to Secretary Yellen heightening their longstanding crypto concerns to specific questions about the extent to which digital assets and exchanges are appropriately captured in AML, sanctions, and CFT regulation. They note in particular the potential for Russia to evade sanctions in the cryptosphere, an issue we anticipated in our policy assessment (see FSM Report SANCTION16).

HFSC Powell Hearing Focuses on Monetary Policy, Geopolitical Risk

As anticipated, today’s HFSC hearing with Fed Chair Powell was almost exclusively focused on Ukraine and the decisions ahead for the FOMC at its mid-March hearing. Mr. Powell made it clear that, while he bemoaned the tragedy unfolding in Ukraine, sanctions policy is outside the Fed’s remit and cyber-risk is being handled to the greatest extent possible. Mr. Powell refused to comment on the Senate stalemate over pending Fed nominations.

Daily030222.pdf

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2 11, 2021

FedFin Assessment: The Near-Term Stablecoin Regulatory Agenda

Arezou Rafikian2023-06-02T13:04:23-04:00November 2nd, 2021|The Vault|

As noted yesterday, the President’s Working Group on Financial Markets (PWG) was joined by the OCC and FDIC yesterday issuing a report calling for prompt Congressional action to regulate stablecoins and, even in its absence, also for fast action by federal regulators and the FSOC. In part because it poses the largest regulatory void, the most worrisome of the risks the report details arises from the role stablecoins may play in the payment system and resulting threats to systemic stability and competition. Issues germane to digital-asset trading (defined to include lending and related activities) are described but largely left to regulators; SEC Chairman Gensler has made it clear (see Client Report INVESTOR19) that he intends to act and the CFTC-chair nominee has done the same.

The full report is available to retainer clients. To find out how you can sign up for the service, click here.

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2 11, 2021

CRYPTO21

Arezou Rafikian2023-06-02T13:03:50-04:00November 2nd, 2021|5- Client Report, Uncategorized|

FedFin Assessment: The Near-Term Stablecoin Regulatory Agenda

As noted yesterday, the President’s Working Group on Financial Markets (PWG) was joined by the OCC and FDIC yesterday issuing a report calling for prompt Congressional action to regulate stablecoins and, even in its absence, also for fast action by federal regulators and the FSOC. In part because it poses the largest regulatory void, the most worrisome of the risks the report details arises from the role stablecoins may play in the payment system and resulting threats to systemic stability and competition. Issues germane to digital-asset trading (defined to include lending and related activities) are described but largely left to regulators; SEC Chairman Gensler has made it clear (see Client Report INVESTOR19) that he intends to act and the CFTC-chair nominee has done the same.

CRYPTO21.pdf…