The PoGo Financial Page
Financial Institutions
October 12, 2007
ATTORNEYS
Gerald L. Blanchard
Inside
FinCEN Indefinitely Delays Implementation of New SAR Forms;
Banks Go Green;
The SEC's and the Federal Reserve's Regulation R;
Avoid Getting Blindsided by Section 409A;
Federal Agencies Implore Lenders to Give a Helping Hand;
Get it in Writing!
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Federal Banking Agencies Release New BSA Manual - 8/12/05
Financial Institutions Client Alert
August 12, 2005
On June 30, 2005, the federal banking agencies jointly released a new Bank Secrecy Act/Anti-Money Laundering Examination Manual. Over the last two years examiners have imposed new requirements on institutions following unfavorable BSA examinations or as part of memoranda of understanding or consent orders. However, it was not always clear that the examiners would expect all institutions to implement the same procedures. The Manual clarifies that many of the requirements we have observed in consent orders and the like are now expected of all institutions.
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Broad Overview of Bank Secrecy Act and Related Compliance Obligations - 01/05
Financial Institutions
February 4, 2005
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Industry Trends To Plan Around in 2005; 2005 Industry Perspective Letter to Clients - 01/05
Financial Institutions
ATTORNEYS
Kathryn Knudson
Walter G. Moeling, IV
Our annual view of industry trends to our clients and friends.
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Expansion and Acceleration of Reporting Requirements Under Current Reports on Form 8-K - 12/04
Financial Institutions
December 23, 2004
This memorandum provides a guide to the Form 8-K requirements and integrates the new amendments with the current disclosure scheme. The discussion opens with a brief overview of the new Form 8-K items and is followed by comprehensive exhibits designed to acquaint you with the expanded disclosure items introduced by the SEC final rule adopting the new amendments.
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Bank Secrecy Act and Related Compliance Concerns - 11/17/04
Fiancial Institutions
November 17, 2004
Ask any banker or bank regulator what their primary compliance concern is this year, and the answer very likely will be the Bank Secrecy Act (BSA). For those bankers that disregarded the Riggs Bank disaster as being unique to large banks or international banks, the $50 million fine levied against AmSouth was a wake up call.
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The American Jobs Creation Act of 2004 - Deferred Compensation Plans - 11/11/04
Fiancial Institutions
November 11, 2004
ATTORNEYS
Richard L. Arenburg
Castles R. Hollis
The American Jobs Creation Act of 2004 made substantial changes to the rules regarding deferred compensation plans and arrangements.
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The American Jobs Creation Act of 2004 - Subchapter S Reforms - 10/04
Financial Institutions
ATTORNEYS
Kathryn Knudson
Walter G. Moeling, IV
The American Jobs Creation Act of 2004 changes the maximum number of shareholders a Subchapter
S company may have as well as the means of counting shareholders.
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SEC Adopts Amendments to Form 8-K - 03/04
Financial Institutions
On March 11, 2004, the Securities and Exchange Commission voted to adopt amendments to Form 8-K. The amendments will add ten disclosure items to Form 8-K, including transferring two items to the current report from the periodic reports on Forms 10-K and 10-Q.
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Narrowing the Graham-Leach-Bliley Privacy "Loophole" of the Gramm-Leach-Bliley Privacy Rules Through Amendments to the Fair Credit Reporting Act - 12/03
Financial Institutions
On December 4, 2003, President Bush signed the Fair and Accurate Credit Transactions Act of 2003 (Public Law 108-159, the FACT Act) to amend the federal Fair Credit Reporting Act (FCRA). This Client Alert summarizes the new information sharing limitations of the FCRA.
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Proposed Regulation K Amendment Bank Secrecy Act - 06/03
Financial Products
On May 28, 2003, the Board of Governors of the Federal Reserve System (the Board) proposed rules to require certain offices of foreign banks (generally, banks organized outside of the United States that receive deposits) to establish procedures to comply with the federal Bank Secrecy Act. Comments on the proposal must be received by the Board by June 30, 2003.
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