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Exam Code: CRCM Practice test 2022 by team
CRCM Certified Regulatory Compliance Manager

A compliance manager's responsibilities generally include direct compliance risk program management and/or validation of compliance risk control effectiveness. The execution of operational business processes incorporating compliance risk controls is not a function or duty generally performed by a compliance manager as a normal and customary job responsibility and thus does not qualify towards meeting the experience requirement.

To satisfy the Professional Experience requirement, primary responsibility for the full range of compliance risk functions is required. Compliance risk functions include, but are not limited to:

Performing compliance risk assessments, audits or examinations, or Developing, implementing, and/or managing all aspects of a compliance risk management program to ensure compliance with U.S. federal laws and regulations.
These jobs are typically found within corporate compliance, legal, audit departments (internal or external), Regulatory Agencies, or dedicated compliance practices within consulting firms. Job responsibilities must be primarily focused on compliance risk management:

Program design, implementation and oversight, Consultation as a subject-matter expert, Administration, enforcement or audit of compliance-related policies, procedures and processes to manage compliance risk, and/or Examination of a bank's compliance program.

Task 1: Act as a compliance subject matter expert on projects and committees.
Task 2: Evaluate development of, or changes to, products, services, processes, and systems to determine compliance risk and impacts and ensure policies remain compliant.
Task 3: Provide compliance support to internal and external parties (e.g., answer questions, review marketing and external communications, conduct research and analysis).
Task 4: Review and/or provide compliance training to applicable parties.
Task 5: Participate in conducting due diligence for vendors.
Task 6: Design and maintain a comprehensive compliance risk assessment program to identify and mitigate risk within the organizations risk appetite.
Task 7: Conduct compliance risk assessments in accordance with the risk assessment program to evaluate relevant information (e.g., inherent risk, control environment, residual risk, potential for consumer harm) and communicate results to applicable parties.

The following knowledge is required to perform the tasks within Domain 1:
• All applicable laws, regulations, and guidance
Other essential CRCM knowledge:
• Risk assessment program scope and objectives
• Compliance risk appetite (e.g., thresholds, escalation points, pass/fail rates)
• Banks products, services, processes, market area, and operations
• Regulatory and industry landscape
• Risk rating methodology
• Key risk indicators (KRIs)
• Volume and severity of known compliance incidents, breakdowns, and/or customer complaints
• Compliance policies, procedures, and other internal controls (e.g., quality assurance, independent testing)
• Exam/audit and internal compliance monitoring results
• Volume and complexity of products, transactions, and customer base
• accurate changes to compliance regulations, key personnel, products, services, systems, and/or processes
• Volume and complexity of products and services provided by third parties

Domain 2: Compliance Monitoring (25%)
Task 1: Define the scope of a specific monitoring or testing activity.
Task 2: Test compliance policies, procedures, controls, and transactions against regulatory requirements to identify risks and potential exceptions.
Task 3: Review and confirm potential exceptions, findings, and recommendations with business units and issue final report to senior management.
Task 4: Validate that any required remediation was completed accurately and within required timelines.
Task 5: Administer a complaint management program.
Task 6: Review first line compliance monitoring results and develop an action plan as needed.
Task 7: Evaluate the reliability of systems of record and the validity of data within those systems that areused for compliance monitoring.

The following knowledge is required to perform the tasks within Domain 2:
• All applicable laws, regulations, and guidance.
Other essential CRCM knowledge:
• Regulator expectations
• Banks products, services, processes, market area, and operations
• Compliance policies, procedures, and controls
• Applicable source data
• Target audience
• Compliance risk rating methodology
• Compliance risk appetite (e.g., thresholds, escalation points, pass/fail rates)
• Complaints received internally and externally, including volumes, sources, trends, and root causes
• Regulatory expectations on complaint management program administration
• Complaint handling procedures
• Critical systems and usage by the business units
• accurate changes to critical systems or processes

Domain 3: Governance and Oversight (10%)
Task 1: Establish and maintain a compliance management policy to set expectations for board, senior management, and business unit responsibilities.
Task 2: Develop, conduct, and track enterprise-wide and/or job-specific compliance training.
Task 3: Conduct periodic reviews of the compliance management program to evaluate its effectiveness and communicate results to appropriate parties.
The following knowledge is required to perform the tasks within Domain 3:
• Regulatory expectations
• Compliance risk appetite (e.g., thresholds, escalation points, pass/fail rates)
• Banks products, services, processes, and operations
• Employee roles and responsibilities
• Compliance risk assessment results
• Regulatory change environment
• Compliance monitoring results
• Compliance audit/exam findings
• Compliance management policy (CMP)
• Volume and severity of known compliance incidents, breakdowns, and/or customer complaints

Domain 4: Regulatory Change Management (15%)
Task 1: Monitor and evaluate applicable regulatory agency notifications for new compliance regulations or changes to existing regulations to assess potential regulatory impacts and remediation needs.
Task 2: Assess new, revised, or proposed regulatory changes for compliance impacts, communicate to the appropriate parties, and develop action plans as needed.
Task 3: Assess regulatory guidance and compliance enforcement actions to determine if remediation is required to address potential compliance impacts.
Task 4: Report on the status of regulatory changes and implementation to appropriate parties.
Task 5: Monitor and validate action plans for confirmed regulatory impacts to ensure timely adherence to the mandatory compliance date.
The following knowledge is required to perform the tasks within Domain 4:
• All applicable laws, regulations, and guidance.
Other essential CRCM knowledge:
• Banks products, services, processes, market area, and operations
• Key stakeholders
• Timeline and extent of impact to business units
• Planned changes to critical systems
• New or revised compliance policies, procedures, controls, and training
• Changes to banks products, services, processes, market area, and operations
• Penalties and potential restitution for non-compliance
• Scope of impacts

Domain 5: Regulator and Auditor Compliance Management (11%)
Task 1: Prepare and review requested audit/exam materials to ensure timely and accurate fulfillment and self-identify potential areas of concern.
Task 2: Participate in audit/exam meetings to provide business overviews, address questions, discuss findings, or provide updates to appropriate parties.
Task 3: Review and draft responses to audit/exam results and ensure action plans are developed and communicated to appropriate parties.
Task 4: Report on action plan status to appropriate levels of management and auditors/examiners.
Task 5: Coordinate and submit ongoing regulatory reports to auditors/examiners.
The following knowledge is required to perform the tasks within Domain 5:
• All applicable laws, regulations, and guidance.
Other essential CRCM knowledge:
• Banks products, services, processes, market area, and operations
• Key stakeholders
• Compliance policies, procedures, and controls
• Critical systems and usage by the business units
• Services provided by third parties
• Compliance risk appetite (e.g., thresholds, escalation points, pass/fail rates)
• Effectiveness of actions taken
• Regulatory expectations
• Top risk, emerging risk, and areas of continued focus
• New bank products, services, processes, market area, and operations

Domain 6: Compliance Analysis and Internal/External Reporting (11%)
Task 1: Analyze and validate data to support regulatory reporting and ensure accuracy and comprehensiveness.
Task 2: Complete required reporting, ensure timely submission to the appropriate agency, and resubmit when required.
Task 3: Develop, implement, and monitor a plan of action to prevent future reporting errors or breakdowns.
The following knowledge is required to perform the tasks within Domain 6:
• Regulation Z (Credit card agreements, marketing on college campuses)
• Regulation II
• Banks products, services, processes, market area, and operations
• Critical systems and usage by the business units
• Findings and root causes
• Compliance policies, procedures, and controls
• Regulator expectations
• Compliance risk appetite (e.g., thresholds, escalation points)
• Penalties and potential restitution for non-compliance
• Scope of impacts

Certified Regulatory Compliance Manager
Banking Regulatory test Questions
Killexams : Banking Regulatory test Questions - BingNews Search results Killexams : Banking Regulatory test Questions - BingNews Killexams : No one cares about the FDIC's state supervisory requirement. So why have it?

Last week Martin Gruenberg, the once and future chair of the Federal Deposit Insurance Corp., went before the Senate Banking Committee to answer senators' questions as part of his confirmation process. Gruenberg — the longest-serving member of the FDIC board, and a veteran of one full term as FDIC chair and several stints as acting chair — was joined by fellow board nominees Travis Hill, who would be vice chair, and Jonathan McKernan. Hill and McKernan are required by statute to belong to a party other than that of the president nominating them.  

While Gruenberg wasn't the only nominee at the hearing, he fielded most of the attention and handled it like a pro, taking in stride the hits regarding the departure of his predecessor, Jelena McWilliams, and patiently answering policy questions in turn. Then at one point Sen. Cynthia Lummis, R-Wyo., posed a question about why exactly none of the nominees have state bank supervisory experience. Below is the entire exchange, and I apologize in advance for quoting at such length.

LUMMIS: I want to turn next to Dodd-Frank. 12 USC 1812 (a)(1) requires that the FDIC board have one member with state bank supervisory experience. That's a quote. State bank supervisor is defined in that same statute as "being an officer of a state with primary regulatory authority over state banks." So this is not only a federal regulator that oversees state banks. So neither Mr. Hill nor Mr. McKernan have experience as a state bank regulator. Mr. Gruenberg, have you worked as a state bank regulator, for a state banking agency?

Gruenberg Hill McKernan
Martin Gruenberg, nominee and acting chair of the Federal Deposit Insurance Corp., was joined by fellow FDIC board member nominees Travis Hill and Jonathan McKernan in the Senate Banking Committee last week.

Amanda Andrade-Rhoades/Bloomberg

GRUENBERG: I have not worked for a state banking agency, Senator. 

LUMMIS: Have you ever written a report of examination or issued an test rating to a community bank, the things that would provide you a good understanding of how fair a bank's test rate is, for example?

GRUENBERG: Well, I would point out that the FDIC supervises, as you know, state-chartered institutions …

LUMMIS: Have you ever written a report of examination?

GRUENBERG: No, I'm not an examiner. I've just served on the board of the agency.

LUMMIS: Do you think someone should have been nominated to the FDIC board with state bank supervisory experience? Because most banks in our dual banking system are state-chartered.

GRUENBERG: They are the majority of the institutions. I understand why you ask the question, Senator, and in a sense … that's also above my pay grade. It's a judgment for the White House in terms of the nominations.

LUMMIS: Well, the statute requires that someone who has actually served as a state bank regulator. That's not you, or any other nominee here. So I think it's pretty clear that the White House and this committee think it's OK to ignore the clear text of Dodd-Frank, and I don't think this committee should move forward with these nominations until we start following the law. 

Lummis's line of argument seems pretty cut and dried — rules is rules, after all. But upon further examination, there's a little more going on here than there might appear at first blush.

The requirement that the FDIC board include one member with state supervisory experience dates back to the go-go '90s, when Congress was actively tinkering with bank regulatory statutes in the wake of the savings and loan crisis of the 1980s. As Jim Cooper, president and CEO of the Conference of State Bank Supervisors, recently noted in these pages in October, the purpose of that requirement was to "ensure the FDIC board included the state banking system's perspective, bringing together both sides of the dual banking system."

In other words, there is value in having someone who knows the state side of the bank supervisory ball in the room when the FDIC is crafting rules. And it's worth noting that these kinds of requirements are all over the financial regulatory apparatus: The FDIC, Securities and Exchange Commission and Commodity Futures Trading Commission (among others) require that their governing boards include a stated number of members of another party than that of the president nominating them — known as minority-party members. 

The Federal Reserve has a requirement similar to the FDIC's that requires "at least one member with demonstrated primary experience working in or supervising community banks having less than $10,000,000,000 in total assets" — a role currently filled by Gov. Michelle Bowman but that was unfilled for years before her nomination. The president is also required to "have due regard to a fair representation of the financial, agricultural, industrial and commercial interests, and geographical divisions of the country" in making Fed nominations — whatever that means. And administrations past and present have been creative in their ways of sidestepping the statutory requirement that no two members of the board may "serve from any one Federal Reserve district." Good thing there aren't two members on the board "from" D.C. or New York.

I'm not trying to dunk on the reasoning behind these statutory requirements. The reason they are there is that there is real value in having rules crafted by a group of people who see things differently or at least from different perspectives and experiences. It is a measure to prevent "groupthink" on the one hand and arrive at better, more durable policies on the other. 

Lummis — and the CSBS, it should be noted — appear to be standing strong in their opposition to these nominees for this reason, but so far it doesn't seem like other Republicans or moderate Democrats intend to go to the mat. And the reason for that is this: If they do, all that will happen is the administration will pull one of the Republican nominees and replace him with one who has state supervisory experience. In other words, this isn't a way for critics of Gruenberg to derail him.

And to put a finer point on it, the FDIC has not brought on a new director with state supervisory experience since Tom Curry, who had been commissioner of banks in Massachusetts, joined the board in 2004. He stayed on until 2017, including five years when he also served as comptroller of the currency.

This is the heart of the problem with these statutory requirements about who can be in the regulatory room: The only effective way to enforce them is through the nomination process, which renders it a political rather than a legal question. I'm not a lawyer, but I did stay in a Holiday Inn Express last night, and I struggle to envision who could credibly establish standing to argue that the confirmation of this slate of candidates caused me personal demonstrable harm that entitles them to redress because none of these nominees have state supervisory experience. So you get what you get and you don't get upset.

I for one think these kinds of requirements have value, but they work the best when they involve passive triggers. For example, the Federal Reserve Act requires that no regional Fed bank president may serve past the age of 65 unless he or she is nominated after the age of 55, and in that case a president may serve for two terms or until the age of 75, whichever comes first. That provision prevents the scenario where someone can be Fed president for life, and the presidents of the Chicago and Kansas City Fed banks are retiring early next year for precisely this reason.

If Congress has decided that it wants certain kinds of people to be in public offices, it has the right to make those decisions — and it has. But these legislative clauses aren't worth very much if they can be so easily sidestepped. Better to either provide them some teeth or take them off the books altogether.

Tue, 06 Dec 2022 10:37:00 -0600 en text/html
Killexams : Fed's Barr builds case for tougher capital requirements

The Federal Reserve's top regulator indicated that higher bank capital requirements and a revamped stress test regime could be in the works.

Fed Vice Chair for Supervision Michael Barr, in a speech delivered at an American Enterprise Institute event Thursday afternoon, detailed the objectives of his "holistic" review of the central bank's capital framework.

Barr took no firm stance on how the Fed's various standards might change, but he said the current calibration appears to be insufficient.

Michael Barr
Federal Reserve vice chair for supervision Michael Barr laid out his vision for a revamped bank capital framework that is more docile and resistant to more variable threats in a speech at the American Enterprise Institute Thursday.

Ting Shen/Bloomberg

"There is a body of empirical and theoretical research on optimal capital, which attempts to determine the level of capital that equalizes the marginal benefits of capital with the marginal costs," Barr said. "While the estimates vary widely, and are highly contingent on the assumptions made, the current U.S. requirements are toward the low end of the range described in most of the research literature."

Since his initial confirmation hearing in front of the Senate Banking Committee in May, Barr has advocated an all-encompassing review of all the Fed's various capital requirements to better understand how they work independently, in conjunction with one another and with other regulatory standards. 

Barr said Thursday that such reviews should be done periodically to ensure bank oversight keeps pace with industry advancements and is positioned to meet future challenges.

Throughout his prepared remarks, Barr emphasized that he would approach the review with an open mind and not to base conclusions on preconceived notions. 

"We are approaching the task with humility," he said, "not the illusion that there is an immutable capital framework to be discovered, but rather, with the awareness that revisions we conceive of today will reflect our current understanding and will inevitably require updating as our understanding evolves."

Still, Barr made the argument that strong capital requirements support banks. He also said the regulatory framework created by the Dodd-Frank Act — which he helped implement as assistant secretary of the Treasury for financial institutions during the Obama administration — helped the U.S. economy grow.

He also pushed back against some of the arguments made by banks and their advocates in favor of less stringent capital rules. Specifically, he rejected the narrative that bank resilience during the COVID-19 pandemic proves that capital standards are already sufficiently high.

Barr said the rapid response by the president and Congress to bolster the economy with fiscal support and the Fed's monetary intervention all meant the capital requirements were never actually put to the test.

"Furthermore, I'd observe that the accurate experience of the pandemic suggests that large, unexpected shocks can occur with little notice," he said. "Our inability to predict such events would argue for a higher overall capital level than one based solely on historical experience."

During a question and answer session following his speech, Barr went further to say that it would be irresponsible to have a regulatory system that relied on banks being bailed out by taxpayers in instances of extreme economic distress.

"We really want to think about capital as having the banks, in this case, internalize the costs that might happen if they were to get into trouble, and that would not include planning on having government support, whether directly or indirectly, to the bank," he said. "It's quite important that we not assume the taxpayer steps in, that we assume rather the opposite, that banks are able to stand on their own bottom and … continue to support the economy."

While all facets of bank regulation are on the table during the current review, Barr flagged stress tests as one area that could see significant changes. He argued against having "static" tests that evaluate banks on similar scenarios year after year, but rather adjusting them to test against a wider variety of disruptions.

"Stress tests are not meant to be predictions about the future. Humility suggests caution in that regard, but they should be stressful," Barr said. "Poking and prodding at the system so we can attempt to uncover hidden risks that could become manifest under certain scenarios. This is particularly important in today's complex and interconnected financial system, in which problems can spread and lead to unexpected losses."

Barr did not provide a timeline for the completion of the review, but noted that he hoped to have a significant update early in the new year.

During the speech — his third since being installed as the Fed's chief regulatory official in July — Barr highlighted the financial stability risks presented by unregulated nonbanks. 

"We need to worry, a lot, about nonbank risks to financial stability," Barr said, "During the global financial crisis, many nonbank financial firms had woefully inadequate capital and liquidity, engaged in high-risk activities, and were faced with devastating runs that crushed the financial system and caused enormous harm to households and businesses."

Insurance companies, government-sponsored enterprises, money market funds, hedge funds and other investment vehicles present a similar — if not greater — risk to today's economy, Barr said. Nonbank financial institutions account for 60% of credit in the U.S. economy, he said, up from 30% in 1980.

Barr acknowledged that stiffer capital standards for banks have fueled the growth of nonbanks, which often have little to no capital requirements, but said that should not be used to justify softening bank capital rules.

"We should monitor the migration of activities from banks to the nonbank sector carefully, but we shouldn't lower bank capital requirements in a race to the bottom," he said. "In times of stress, banks serve as central sources of strength to the economy, and they need capital to do so."

This stance seems to contradict a policy argument made by another Fed Board member just hours before. During an event hosted by the investment bank KBW on Thursday morning, Fed Gov. Michelle Bowman advocated for a regulatory regime that made it easier for banks to re-enter businesses that they have been squeezed out of in accurate years.

"In my mind, it's important that we work to specifically further the ability for banks to participate in those traditional activities that they have been very successful in providing services in and not unintentionally or intentionally push those services outside the regulated banking sector," Bowman said.

During the question and answer portion of the AEI event, Barr elaborated on his views, saying he favors applying more regulation to nonbanks to minimize risks. He said this could be done, in some instances, under provisions of Dodd-Frank that allow for entities to be deemed financial market utilities or nonbank systemically important financial institutions to bring them within the regulatory perimeter. 

In this regard, Barr and Bowman seem to be more in alignment. On Thursday, Bowman said she supported applying stricter regulations to banklike activities occurring outside the banking sector. "If it's the same product, the same risk, we have to have the same regulation," she said.

Thu, 01 Dec 2022 12:51:00 -0600 en text/html
Killexams : Compliance Update — Insights and Highlights

Thursday, December 1, 2022

The world of banking compliance is constantly changing, and bankers have an increasing amount of information to keep up with in order to stay informed. This column will be used periodically to highlight compliance-related issues that may be of interest to those in your institution.


The Consumer Financial Protection Bureau (CFPB/Bureau) has been busy this year, and its agenda does not seem to be getting any shorter as the year gets closer to the end. Before moving into accurate happenings at the CFPB, it is important to mention what is currently one of the “hottest” Topics in the banking world — the October ruling by a panel of three Fifth Circuit judges that the funding structure of the CFPB is unconstitutional pursuant to the Appropriations Clause. Many of you may have cheered when you first read the headlines, but there are many unanswered questions, an appeal process, and much more to come on the topic. All that said, do not use this ruling as an excuse to slack on compliance; a resolution could be years in the making.

The CFPB has started the process of drafting a new consumer data rights rule. The Bureau is currently asking for comments from institutions (i.e., financial institutions pursuant to Regulation E, credit card issuers pursuant to Regulation Z, and companies providing electronic funds transfers) that will likely be subject to the rule. As currently drafted, the rule would allow consumers to access account-related financial data, such as transaction history, costs, usage, etc., in an effort to foster competition and consumer choice. The Bureau is currently seeking industry guidance regarding the scope of the rule, permitted recipients of the requested financial data, a third party’s use of the data, compliance concerns, applicable data and its availability, and an effective date. The comment period is set to expire January 25, 2023.

Additionally, the Bureau issued Consumer Financial Protection Circular 2022-07 on November 10, 2022, addressing inadequate investigation practices by consumer reporting companies and providing related guidance. The guidance was issued as a result of the CFPB’s finding that some consumer reporting companies (including furnishers) failed to properly investigate consumer disputes. Such failures could result in liability for the companies and furnishers under the Fair Credit Reporting Act. The guidance reiterates specific responsibilities related to investigations. First, upon notice of a dispute, a consumer reporting agency must notify the furnisher and provide it with all relevant information related to the individual involved in the dispute. Consumer reporting agencies and furnishers must conduct a reasonable investigation of all disputes received directly from a consumer regardless of the manner in which it was made aware of the dispute. Furnishers must investigate all disputes received from a consumer reporting agency no matter the means by which the dispute is made. The CFPB used the guidance to communicate all applicable companies of the “serious consequences” that may arise for failure to conduct reasonable investigations of such disputes because of the “destructive consequences” that just one incorrect piece of information may potentially have on a consumer’s credit.

Another CFPB Consumer Financial Protection Circular that was published in October regarding “illegal junk fees on deposit accounts” is the subject of a separate article in this newsletter. It is worth mentioning that the CFPB has noted in the circulars that these publications are “policy statements advising parties with authority to enforce federal consumer financial law.” In other words, the CFPB expects other regulatory agencies to accept the views expressed through each circular and to regulate the entities within each agency’s jurisdiction accordingly.

False Claims Act Settlement with PPP Lender

The Department of Justice (DOJ) entered into an $18,000 settlement with a Texas bank resulting from its alleged improper processing of a Paycheck Protection Program (PPP) loan. This is the first settlement with a PPP lender pursuant to the False Claims Act. In the case, the PPP application included a question regarding the applicant’s criminal involvement (or that of anyone owning more than 20% equity of the company); specifically, whether the applicant or applicable equity owner was subject to an indictment, a criminal information, or an arraignment, or was facing criminal charges. The applicant responded negatively to this question, but the DOJ alleged that bank employees were aware of criminal charges against the owner. The DOJ claimed that the bank was not entitled to the $10,670 fee it received for processing the application because the applicant was ineligible for the loan due to his criminal charges (and ultimate guilty plea to a misdemeanor violation for which he was fined $1,000).

Annual Threshold Adjustments

The CFPB, the Federal Reserve, and the Office of the Comptroller of the Currency have recently adjusted the thresholds for exemptions and appraisals in the Truth in Lending Act (TILA) Higher Priced Mortgage Loan Appraisal Rule. The exemption threshold for appraisals for higher-priced mortgage loans will increase from $28,500 in 2022 to $31,000, effective January 1, 2023. Additionally, the CFPB and the Fed have made adjustments to the consumer leasing exemption threshold pursuant to Regulation M. Effective January 1, this threshold will increase from $61,000 to $66,400. These agencies also adjusted the TILA exemption threshold from $61,000 to $66,400, effective January 1.

Bank Secrecy Act/Anti-Money Laundering (BSA/AML)

Advances in technology are rapidly changing the world of banking, including BSA/AML compliance. Cybersecurity is an important focus for all organizations, especially banks. The US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) recently reported that the total dollar value of ransomware-related BSA filings in 2021 was close to $1.2 billion, a substantially significant (188%) increase from the $416 million in 2020. FinCEN suggested that this increase could be the result of either an increase in incidents or an improvement in detecting potential incidents. According to FinCEN, the number of Suspicious Activity Reports filed pursuant to a cyber event increased by 74% from 2020 to 2021. It is likely that there will be another large increase once 2022 information is available. This is just a reminder to stay diligent and aware of potential threats, especially during this holiday season. As a result of this increase and other cybersecurity-related BSA threats, the Federal Financial Institutions Examination Council (FFIEC) recently updated its 2018 Cybersecurity Resource Guide for Financial Institutions and replaced it with the 2022 FFIEC Cybersecurity Resource Guide for Financial Institutions. The guide is provided as a tool for financial institutions to use in an effort to prepare for and respond to cyber incidents. The guide now includes ransomware-specific information for banks and other financial institutions to use to mitigate risks related to ransomware. The FFIEC included updated resource links for the following categories: assessment, exercises, information sharing, and response and reporting.

Peer-to-Peer (P2P) Payments

The American Bankers Association (ABA) is continuing the discussion on the impacts of advances in technology and recently wrote a letter to the CFPB addressing P2P payments. The purpose of the letter was to inform the Bureau of the efforts banks are making related to P2P payments in order to prevent fraud, educate consumers on how to avoid becoming victims, and identify the burdens banks are facing. The ABA informed the CFPB of the many resources it makes available to banks free of charge in an effort to increase consumer education about fraud prevention. In its letter, the ABA presented facts in support of its stance that shifting liability from the consumer to the bank in instances of fraud resulting from a consumer-initiated transaction would increase consumer costs and decrease competition. Further, the ABA set forth that such a shift will lead to a profit for scammers because there will be no risk for a consumer to send money if the bank is going to ultimately reimburse the consumer. The ABA urged the CFPB to work in conjunction with the banking industry, the non-bank P2P service providers, law enforcement, the Federal Trade Commission, and others who may work together to prevent scams, reduce fraud, and decrease consumer harm.

These are just the highlights of accurate happenings in the world of compliance. There is much more to come, and it is sure to be another eventful year as 2023 will likely begin with many unanswered questions and unresolved issues related to the CFPB, P2P liability, increased cyber threats, expected Community Reinvestment Act final rules, the continued focus on fair lending and redlining, and much more.

Wed, 30 Nov 2022 10:00:00 -0600 en text/html
Killexams : FTX’s banking ties raise uncomfortable questions for regulators

Federal watchdogs have for months been warning banks to tread carefully with digital assets.

The residue of Sam Bankman-Fried’s crypto empire is laying bare the industry’s growing foothold in the traditional banking system.

Although there is no indication that FTX’s spectacular collapse poses any systemic risk, its bankruptcy filings read like a warning label on what could go wrong. The disclosures also raise a pressing question for US regulators and lenders: Are they doing enough to keep tabs on the fast-growing sector?

Federal watchdogs have for months been warning banks to tread carefully with digital assets, and, for the most part, Wall Street has heeded that call. Some smaller American lenders have eagerly courted business from crypto firms, including those based abroad.

“How does the US government protect US consumers from a Bahamas-based crypto exchange?” said Kevin Carr, a financial industry consultant and former Treasury Department official, referring to FTX. “There’s no easy answer to that, but it does underscore the problem of jurisdiction-shopping where a company will choose to base itself in a country with less stringent oversight.”

FTX has listed in bankruptcy filings Silvergate Capital Corp. and Signature Bank, which are both federally regulated by the US, as places where it or related entities had accounts. It also highlighted Bahamas-based Deltec Bank & Trust, which isn’t directly overseen by Washington but is well-known in the crypto world.

All three institutions have sought to explain that their exposure to the turmoil was limited.

Silvergate has said FTX-related deposits represented less than 10% of the $11.9 billion held for digital asset customers as of Sept. 30. Signature cited an even smaller percentage — of less than 0.1% of its overall deposits as of November 14 — and said its deposit base has held steady since the exchange’s collapse. Meanwhile, Deltec said on its website that it has “no credit or asset exposure to FTX.”

Deposit accounts

The links, however, extend beyond deposit accounts, the bankruptcy filings show. They pointed to a surprising development that a venture capital fund tied to Bankman-Fried’s Alameda Research hedge fund invested $11.5 million in Farmington State Bank, which does business as Moonstone Bank in Washington state.

Moonstone said in a statement on Tuesday that it received Alameda’s investment in January as part of a capital raise, when the company “had a pristine reputation and was a darling of the financial markets.”

The share represents less than 10% of Moonstone, it said.

‘‍‘Alameda has a non-controlling interest in Moonstone, with no board membership and no involvement with management,” it said. The bank, which transformed its business model following its 2020 acquisition by FBH Corp., said it has remained in close communication with regulators and added controls “to ensure all our activities comply with all applicable laws and regulations.”

Sam Bankman-Fried

The Washington State Department of Financial Institutions said the investment didn’t require regulatory approval because it did not constitute a controlling interest in the business.

It’s not just smaller banks or regional lenders that have sought to capture crypto business. Some of Wall Street’s bigger firms have started offering crypto services including some trading, wealth management and advisory, which are typically less risky to their businesses than accepting crypto deposits or investments.

Bank of New York Mellon Corp. in October launched a US digital asset platform allowing some clients to hold and transfer Bitcoin and Ether, which it said is the first by a global bank to provide such services.

In comments that now seem prescient, Fed Vice Chair Michael Barr said in October that banks should be cautious in their partnerships with crypto firms, given the interconnectedness between digital-asset companies exposed by the accurate failures in the market.

Barr also warned that working with crypto companies can expose banks to risks including fraud, theft, manipulation, and money laundering.

Neither US federal nor state regulators have accused Silvergate, Signature, Deltec, or Farmington State Bank of any wrongdoing in their dealings with FTX.

Representatives for the Federal Reserve, the Federal Deposit Insurance Corp (FDIC) and the Office of the Comptroller of the Currency all declined to comment on whether the FTX filings spotlight regulatory blind spots.

‘Reckless’ risks

On Wednesday, Sherrod Brown, the head of the Senate Banking Committee, urged US Treasury Secretary Janet Yellen to work with lawmakers to craft crypto legislation that tackles risks exposed by FTX’s collapse.

“As we continue to learn more details, the failure of this crypto exchange brings to mind the litany of financial-firm failures due to the combination of reckless risk-taking and misconduct,” Brown, an Ohio Democrat, said in a letter to Yellen. “Congress and the financial regulators must work to get all of this right.”

Janet Yellen

Yellen, for her part, said at a New York Times event Wednesday that the FTX debacle was “the Lehman moment within crypto,” referring to the collapse of investment-banking giant Lehman Brothers Holdings Inc. in 2008 that crippled global credit markets.

“We have consistently urged regulatory gaps be closed,” Yellen said.

“This experience with his firm, or set of firms, just couldn’t provide a better illustration. These are very risky assets, but the good piece of an explosion like we saw is it hasn’t spilled over to the banking sector.”

FTX blowup

To be sure, even before FTX’s blowup, federal regulators were grappling with how to deal with crypto ties to traditional finance.

Throughout 2022, the FDIC has been trying to crack down on companies, including FTX and Voyager Digital LLC, over claims they may mislead investors into thinking their money was covered by deposit insurance. Both firms are now bankrupt.

In the case of Voyager, the crypto platform said in some materials that US dollar deposits with the firm were covered by FDIC insurance, in the event of either the crypto company or the bank’s failure. In reality, while Voyager’s banking partner Metropolitan Bank Holding Corp. was insured, Voyager wasn’t, meaning clients wouldn’t benefit from the insurance if Voyager went under.

Meanwhile, banks and the trade groups that represent them have said they lack clarity from Washington regulators on how to engage in crypto activities, including through partnerships with digital-asset firms and fintechs.


Sultan Meghji, a former chief innovation officer for the FDIC, acknowledged that bank regulators have been struggling with how to handle those partnerships and said watchdogs could be doing “a lot more.”

In the meantime, however, Meghji said he expects banks offering services to crypto companies to face a lot more scrutiny following the FTX failure. He said that firms should consider doing more self-policing so that they’re not liable for any misconduct.

“I would do a complete audit of all of my banking as a service customers and look at beneficial ownership of all of those customers to ensure that I have not — knowingly or not — gotten in bed with the next FTX,” Meghji said.

© 2022 Bloomberg

Wed, 30 Nov 2022 19:10:00 -0600 en text/html
Killexams : Nvidia and Deutsche Bank team up to deliver enhanced, AI-powered financial services

Nvidia Corp. today announced a multiyear “innovation partnership” in which it will work closely with Germany’s Deutsche Bank AG to accelerate the use of artificial intelligence and machine learning technologies in the financial services industry.

The partnership, announced today, is all about fulfilling the potential of AI and machine learning in the banking sector. The two companies, which have been working on the partnership for the past 18 months, plan to develop a wide range of regulatory compliant AI-powered services. In addition, Deutsche Bank said working closely with Nvidia will enable it to accelerate its digital transformation efforts by using AI to simplify and accelerate decisions around cloud migration, for example.

The two companies are planning to collaborate in many different areas, but the one with the most potential is risk model development. Important tasks in the banking sector, such as price discovery, risk valuation and model backtesting, involve doing lots of computationally intensive calculations. These are traditionally done using massive central processing unit-driven server grid farms.

However, Deutsche Bank said it will instead tap Nvidia’s expertise in accelerated computing, powered by graphics processing units and coupled with AI, to enable traders to manage risk better by running more scenarios faster. Deutsche Bank said many functions that were typically processed overnight, such as risk valuation, can now be performed in real time thanks to Nvidia’s accelerated compute.

As part of the collaboration, Deutsche Bank said it will leverage the Nvidia AI Enterprise platform that’s used to streamline the development of AI models on-premises or in the cloud. This will provide it the flexibility it needs to run AI workloads wherever they’re required, the bank explained.

“Accelerated computing and AI are at a tipping point, and we’re bringing them to the world’s enterprises through the cloud,” said Nvidia founder and Chief Executive Jensen Huang. “Every aspect of future business will be supercharged with insight and intelligence running at the speed of light. Together with Deutsche Bank, we are modernizing and reimagining the way financial services are operated and delivered.”

Deutsche Bank is also looking at ways in which AI can be used to deliver new, interactive experiences for employees, potential recruits and customers that involve using 3D virtual avatars, it said. During its exploratory work with Nvidia, Deutsche Bank used Nvidia’s Omniverse Enterprise platform to create a 3D virtual avatar to help new employees navigate internal banking systems and respond to questions from its human resources department. Looking ahead, Deutsche Bank will work with Nvidia to create additional immersive metaverse experiences for its banking clients, with digital avatars and virtual assistants powered by AI.

Another major use case Deutsche Bank is looking into is the extraction of useful insights from the masses of unstructured data it collects. While AI has already proven its worth in data analytics in the past, the problem for banks is that existing models don’t perform very well when it comes to unstructured, financial texts. Deutsche Bank is instead looking to use new neural networks known as “transformers” to Excellerate this. It explained that a single, pretrained transformer model is capable of performing amazing feats already, including text generation, translation and even software programming.

As such, Deutsche Bank has already begun working with Nvidia to test a collection of AI models called “Finformers,” or financial transformers, that can tap unstructured data to spot early warning signs of counterparty risk, fraud, issues with data quality and more.

Finally, Deutsche Bank said it’s planning to work with Nvidia to expand its existing internal AI center of excellence to support the experimentation and development of AI services and professional skills development. Ultimately, it wants to develop, foster and promote explainable and responsible AI models that can expand its understanding of AI predictions in financial services.

“This partnership is a significant step forward in our AI and ML ambitions,” said Bernd Leukert, a Deutsche Bank board member responsible for technology, data and innovation.

Photo: Nvidia

Show your support for our mission by joining our Cube Club and Cube Event Community of experts. Join the community that includes Amazon Web Services and CEO Andy Jassy, Dell Technologies founder and CEO Michael Dell, Intel CEO Pat Gelsinger and many more luminaries and experts.

Wed, 07 Dec 2022 04:42:00 -0600 en-US text/html
Killexams : FINRA Facts and Trends: November 2022

Wednesday, November 30, 2022

Welcome to the latest issue of Bracewell’s FINRA Facts and Trends, a monthly newsletter devoted to condensing and digesting accurate FINRA developments in the areas of enforcement, regulation and dispute resolution.  This month, we report on FINRA’s targeted sweep of crypto-related communications, further proposed amendments to the expungement rule, and FINRA’s crack down on small-cap IPOs, Read about these issues, along with notable enforcement actions and arbitration decisions, below.

FINRA Announces Targeted Sweep of Crypto Purveyors

Earlier this month, FINRA launched a targeted examination into cryptocurrency-related communications made by broker-dealers and their affiliates. Whether this examination was triggered by the stunning collapse of crypto exchange FTX or whether the timing was purely coincidental, FINRA has clearly signaled that it is ready to take a harder line on transactions involving digital currency.

FINRA’s sweep focuses on retail communications made by brokers or their affiliates in the third quarter of 2022 that involved a crypto asset or a service involving the transaction or holding of a crypto asset. The examination letter defines “crypto asset” as any asset “issued or transferred using distributed ledger or blockchain technology,” whether described as a currency, coin or token. And “communications” include not just written and electronic messages, but also video, social media posts, websites and private messages posted on mobile applications like WhatsApp (another issue being followed closely by FINRA).

Firms receiving FINRA’s test letter must disclose details about the communications themselves, including internal approval processes as well as whether the communications were filed with FINRA’s Advertising Regulation Department.  FINRA is also seeking to review each target firm’s supervisory procedures, compliance policies, manuals or other guidance regarding such communications. Finally, FINRA seeks information on how broker-dealers use affiliates to offer crypto assets.

Generally speaking, FINRA uses targeted exams to gather information and carry out investigations, especially in response to emerging issues.  According to FINRA, the firms included in a sweep are selected based on a variety of factors, including level and nature of business activity in a particular area, customer complaints and regulatory history, and prior examination findings.

This month’s action on cryptocurrency communications presents the latest step in FINRA’s attempts to monitor digital asset sales.  Since 2018, FINRA has been issuing yearly notices encouraging firms to notify FINRA if they engage in activities related to digital assets.  In October 2021, FINRA released a regulatory notice concerning FinCEN’s anti-money laundering priorities that highlighted “virtual currency considerations.”  And this past January, as reported by Barron’s, FINRA CEO Robert Cook announced potential changes to cryptocurrency advertising and disclosure requirements at a Securities Industry and Financial Markets Association (SIFMA) event.

Proposed Expungement Rule Delayed Again

As we reported previously, FINRA proposed an overhaul of the customer complaint expungement process back in July 2022. On November 10, 2022, after receiving dozens of comments from industry advocates, and one day before the Securities and Exchange Commission was set to rule on the proposal, FINRA filed an amendment that would further tighten the expungement process. The proposed amendment contains three modifications that are designed to meet the concerns of certain investor advocates. First, the amendment would forbid brokers from seeking expungement if that broker had previously been found liable for that same matter by a panel or court of competent jurisdiction. Second, the amendment would clarify that customers whose complaints are the subject of an expungement request are entitled to participate in “all aspects” of the expungement process. Third, the amendment makes clear that arbitrators should not “give any evidentiary weight” if a customer elects not to participate or attend an expungement hearing. Assuming these latest amendments do not generate further concerns by industry or investor advocates, the new expungement rules could go live in early 2023.

Notable Enforcement Matters and Disciplinary Actions

  • Falsifying Client Statements.  On November 4, 2022, Wedbush Securities agreed to pay $850,000 in fines to settle allegations that it falsified monthly account statements for five years from 2013 to 2018.

    In its Letter of Acceptance, Waiver and Consent, FINRA said that the Los Angeles-based wealth management, brokerage and clearing firm “negligently misrepresented on monthly account statements that it sent to approximately 610 customers that certain corporate and municipal bonds were making interest or principal payments when, in fact, the bonds were in default.” Although Wedbush allegedly received notifications that the bonds were in default, it failed to pass along that information to customers. The AWC also alleges that Wedbush did not reasonably review the accuracy of account statements even after being notified by a vendor that it was misreporting information.

Notable FINRA Arbitration Awards

  • Options trading.  In our previous several issues, we have reported on a series of customer arbitration proceedings related to investments in a securities broker-dealer’s managed account options trading strategy.  accurate decisions have skewed toward victories for the broker-dealer, with a new award issued this month continuing that trend.

    • FINRA Case No. 19-02173 – A three-arbitrator panel conducted a six-day hearing in New York on claims of unsuitability and misrepresentations related to an individual Claimant’s investments in the options trading strategy, seeking $700,000 in compensatory damages, and more than $2 million in punitive damages.  Following the hearing, the panel dismissed the claims and recommended expungement of the claims from an associated person’s CRD records.  In recommending expungement, the panel noted that the claims of unsuitability were withdrawn at the hearing, while the facts at the hearing established that no misrepresentations had been made in connection with the Claimant’s participation in the options strategy.

  • Investment Banking Fees.  Two awards were issued this month in cases brought by Intellivest Securities, Inc., a Georgia-based investment banking company, on claims that counterparties to its investment banking agreements failed to pay one or more fees for Intellivest’s investment banking services.

    • FINRA Case No. 20-04131 – Following a three-day hearing, a three-arbitrator panel dismissed in their entirety claims brought by Intellivest against Rethink Community, LP and Rethink Management, LLC, seeking $300,000 for alleged breach of an investment banking agreement. 

    • ​​​​​​​FINRA CASE No. 20-03652 – After conducting a four-day hearing in Wilmington, Delaware, the parties apparently reached a settlement in the principal amount of $24,000.  The three-arbitrator panel in the proceeding nevertheless issued an award, granting Intellivest pre-judgment interest on the settlement amount, plus $10,500 in expert costs.  The panel further assessed the entirety of the forum fees to Respondents Gratitute Management LLC and The Builders Fund, LP, based on the Panel’s finding that Respondents were “inattentive” to their obligations under contract and law.

  • Individual Retirement Accounts (IRAs).  Two awards were issued this month that granted damages and equitable relief to Claimants in connection with claims of improper tampering with their IRAs.

    • FINRA Case No. 21-02340 – Claimants in this arbitration alleged that Respondent Lincoln Financial Advisors Corporation conducted an unauthorized liquidation of Claimants’ IRAs, which the Statement of Claim described as “unauthorized panic selling.”  A three-arbitrator panel, following a four-day hearing, dismissed the claims for violation of the securities laws, but granted the Claimants $100,000 on their claims for failure to supervise, and further directed that one of the two IRAs in question be reinstated “as if it had remained invested as of March 11, 2020.”

FINRA Notices

  • Regulatory Notice 22-23 – FINRA provided guidance to member firms and? registered representatives on developing succession plans for their customers.  Such succession plans often come into play when a firm or representative leaves the brokerage industry, such as in retirement, due to disability or illness, or, primarily in the case of small firms, upon the sale of a brokerage firm. 

    The Notice discusses the background and emerging trends with respect to succession plans, and provides member firms and representatives with an overview of the governing FINRA rules and important considerations surrounding succession planning.  While this Regulatory Notice creates no new rules or regulatory framework for succession plans, the guidance it provides can be used by member firms to review and modify their WSPs and business practices to achieve compliance with their regulatory obligations.

  • Regulatory Notice 22-24 – FINRA amended Rule 11880, concerning the settlement of syndicate accounts in connection with offerings of corporate debt securities.  While the current rule requires only that syndicate accounts be settled within 90 days from the date on which the corporate securities are delivered by the issuer, the new rule will require 70% of the gross amount due to each syndicate member to be remitted within 30 days, with final settlement of the remainder to occur within 90 days.

    In its filing approving the rule change, the SEC explained that the amendment seeks to reduce the risks associated with syndicate debt issuance, including most notably the exposure of syndicate members to the potential deterioration of the credit of syndicate managers during the pendency of account settlement.  

  • Regulatory Notice 22-25 – FINRA issued an alert concerning a accurate trend in initial public offerings (IPOs) for certain small-cap issuers, pointing to a heightened threat of fraud.  Specifically, FINRA has observed unusual price increases occurring the day of or shortly following small-cap IPOs, especially those involving issuers with operations in other countries.  FINRA notes its concerns that these issuers may be the subject of “pump-and-dump-like schemes,” and encourages members to immediately report potential fraud.

Tue, 29 Nov 2022 10:00:00 -0600 en text/html
Killexams : Fed banking supervisor eyes ‘holistic’ review of bank regulations while doubling down on protections they offer

The Federal Reserve’s principal regulator of the banking industry, Michael Barr, on Thursday reiterated plans to study capital requirements and other safeguards to protect lenders and consumers in a downturn, and said more specific proposals from the central bank would come early in 2023.

The U.S. Federal Reserve will soon launch a holistic review of its full range of regulations as part of Barr’s effort to adapt the banking system to address emerging risks. That review could include consideration of higher capital requirements,...

Thu, 01 Dec 2022 07:10:00 -0600 en-US text/html
Killexams : After Months at Arm’s Length, Sen. Brown Opens Door for Crypto Legislation

U.S. Sen. Sherrod Brown (D-Ohio), the chairman of the Senate Banking Committee, has widely been seen as the linchpin of legislation to set up oversight of the cryptocurrency industry. While his crypto suspicions have been clear in hearings, his plans for specific bills remained quiet until now.

Brown sent a letter Wednesday to U.S. Treasury Secretary Janet Yellen, for the first time outlining his willingness to work on legislation and the broad strokes of what that legislation should look like – including that the approach must be comprehensive and rope in all the relevant financial agencies.

“Single regulatory agencies currently generally do not have a comprehensive view of crypto asset entities’ activities,” Brown argued in his letter, which highlighted the findings of a report from the Financial Stability Oversight Council led by Yellen, including its recommendation for legislation that would “create authorities for regulators to have visibility into, and otherwise supervise, the activities of the affiliates and subsidiaries of crypto-asset entities.”

He said he wants to “work on such legislation,” especially in light of the collapse of crypto exchange FTX that destroyed many Americans’ investments.

While the work on legislation is underway, he said U.S. financial agencies should keep up vigorous enforcement actions and “take on the significant noncompliance with current law among crypto-asset firms.”

Brown’s remarks, however, don't reveal his views on existing legislative efforts. His position on a bill to regulate stablecoins, for instance, will be key, because such a bill – like those being negotiated in the House Financial Services Committee and by other lawmakers on his committee – will likely need his support. Brown hasn’t openly shared his view on more comprehensive efforts, such as the proposals from leading members of the Senate Agriculture Committee.

Meanwhile, at his committee’s hearing on nominations for Federal Deposit Insurance Corp. board members on Wednesday, Brown again made his crypto suspicions clear.

“We can't let thousands of risky and volatile assets that are used only for speculation and sanctions evasion into our banking system, and we know that it’s a national security issue,” Brown said.

Yellen said at a separate event on Wednesday that the drama over FTX proves that this industry needs to have strong rules, “and it doesn’t.”

“To the extent that the crypto world could deliver faster, cheaper, safer transactions, we should be open to financial innovation,” she said at the New York Times' Dealbook Summit in New York. “That said, that's not what most of it has been about.”

Brown asked the nominees at Wednesday’s hearing, “Is there any public purpose to crypto right now?”

“Right now, most of the public promise of crypto is for the future,” said Travis Hill, a Republican who President Joe Biden nominated to be the FDIC board’s vice chairman. “As of today, most of that is theoretical and not part of everyday life.”

For his part, another Republican board nominee, Jonathan McKernan, suggested that the FDIC – one of the three primary U.S. banking regulators – may not be as relevant as the Securities and Exchange Commission and the Commodity Futures Trading Commission for directing crypto oversight.

“There are some significant open questions as to what is a permissible activity when it comes to crypto at a bank,” McKernan said. “I think there is a role for the market regulators to play in continuing to define the rules of the road in this space, and the banks will need to similarly comply with that law."

The hearing otherwise revealed a position solidifying among some Democrats on digital assets. Apart from Brown’s views, other Democrats also argued against exposing the banking system to cryptocurrency risks.

“I don't think crypto passes the smell test,” said Sen. Jon Tester (D-Mont.). “I don't want to provide it credibility by regulation.”

Sen. Elizabeth Warren (D-Mass.) may have been the hearing’s loudest anti-crypto voice, though.

“If the crypto boosters had gotten their wish and a bunch of banks that the FDIC insures were all-in on crypto – for example, holding FTX’s tokens on their balance sheets or accepting crypto tokens as collateral for loans – would our banking system be less safe than it is today?"

“I would think so,” said Martin Gruenberg, the FDIC’s acting chairman who is nominated to again be its chairman. “The failure of those firms was really limited to the crypto space and ended up not impacting the insured banking system.”

Wed, 30 Nov 2022 04:28:00 -0600 en text/html

DALLAS, Nov. 30, 2022 /PRNewswire/ -- Bradley Arant Boult Cummings LLP is pleased to announce that Jera L. Bradshaw has joined the firm's Dallas office as counsel in the Banking & Financial Services Practice Group.

Ms. Bradshaw brings more than 13 years of experience advising banks and their regulators on a wide range of regulatory, compliance, and transactional matters. She excels at building trusting business relationships, directing multi-functional teams, and presenting strategic and risk-management recommendations to key organizational leaders. Prior to joining Bradley, Ms. Bradshaw served as vice president and senior counsel of Regulatory Affairs for a regional banking organization, where she advised the enterprise on U.S. banking laws and regulations, as well as other complex legal, regulatory, and compliance matters.

Her bank regulatory and enforcement experience includes eight years serving as senior attorney for the Federal Deposit Insurance Corporation (FDIC), Dallas Regional Office. In that role, she conducted investigations of banks and individuals for potential violations of banking law and oversaw enforcement actions involving safety and soundness issues, compliance management system risk, and consumer protection laws. She also provided legal advice on a wide range of federal banking laws and regulations applicable to bank activities such as transactions between affiliates, equity investments, loans to insiders, and mergers and acquisitions. She began her banking regulatory career as an attorney with the Tennessee Department of Financial Institutions, providing legal counsel on legislation, laws, and policy affecting financial institutions in Tennessee.

"Adding Jera to our team continues Bradley's long-standing commitment to offering high-quality, practical legal advice to our banking and financial services clients in Texas and across the country," said Robert Maddox, chair of Bradley's Banking and Financial Services Practice Group. "Jera's background as both a regulator and as a key member of the in-house counsel team for lending banks will prove to be invaluable to our clients."

A graduate of the University of Memphis Cecil C. Humphreys School of Law, Ms. Bradshaw received her B.A. from Rhodes College. She is an active member of the Junior League of Dallas.

Bradley's Banking & Financial Services Practice Group counsels financial services clients on their unique and particularly complex legal needs, whether those pertain to litigation, regulations and compliance, corporate matters, or other operational matters that banks may face on a daily basis. The team represents a broad range of banks, lenders, and financial institutions across the U.S., serving in the role of "outside general counsel" by providing guidance on a spectrum of legal issues including regulatory compliance, governmental investigations, risk assessments, audit and test support, business transactions, litigation and multi-state settlements.

About Bradley
Bradley combines skilled legal counsel with exceptional client service and unwavering integrity to assist a diverse range of corporate and individual clients in achieving their business goals. With offices in Alabama, Florida, Mississippi, North Carolina, Tennessee, Texas, and the District of Columbia, the firm's more than 600 lawyers represent regional, national and international clients in various industries, including banking and financial services, construction, energy, healthcare, life sciences, manufacturing, real estate, and technology, among many others. 


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Wed, 30 Nov 2022 02:40:00 -0600 text/html
Killexams : HashKey Group and SEBA Bank Form Strategic Partnership to Accelerate Institutional Adoption of Digital Assets in Hong Kong and Switzerland No result found, try new keyword!HashKey Digital Asset Group (" HashKey " or " The Group ") and SEBA Bank AG (" SEBA Bank ") have today announced a new strategic partnership that will see both financial services groups leverage their ... Sun, 04 Dec 2022 16:35:00 -0600 en-US text/html
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