February 27, 2024
To our clients and friends:
Item 402(x) of Regulation S-K, promulgated as part of the SEC’s final rule on insider trading arrangements, is effective today. Item 402(x) will require additional narrative disclosure of internal policies and practices governing the timing of stock option grants, as well additional tabular disclosure if stock option grants are made in proximity to the release of material nonpublic information.
Our Alert regarding the requirements and certain changes issuers should consider is available here.
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February 9, 2024
To our clients and friends:
On January 29, the OCC proposed a rule to amend its procedures for evaluating bank mergers and to incorporate a policy statement summarizing the principles the agency will use when it reviews proposed bank mergers going forward. Out Client Alert describes the most relevant procedural changes and significant aspects of the new policy statement, and includes key takeaways that will be important for banks considering future merger and acquisition activity. Our Alert regarding the OCC’s proposed changes to its bank merger review process is available here.
Luse Gorman has acted as counsel on more than 100 bank M&A transactions during the past five years and more bank M&A transactions than any other law firm in the nation over the past 20 years. Luse Gorman regularly works with federal and state banking agencies to seek regulatory approval for business transactions, including mergers and acquisitions, and routinely handles complex and novel legal questions on behalf of its clients as they arise. To learn more about our firm and services, please visit our website.
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February 5, 2024
To our clients and friends:
Today we published Volume 2 of The Bankers’ Bulletin. You can find a copy of this edition here.
This volume covers recent CFPB proposed rules on overdraft and other fees, FRB and NYDFS enforcement actions for disclosure of confidential supervisory information, the Acting Comptroller’s thoughts on liquidity risk, changes to the bank agencies’ administrative processes, and notable developments related to national bank preemption and special purpose bank chartering.
If you have any questions related to any of the items covered in the Bulletin, please reach out to Brendan Clegg (bclegg@luselaw.com), Marc Levy (mlevy@luselaw.com), Agata Troy (atroy@luselaw.com), or your regular Firm contact. To learn more about our firm and services, please visit our website.
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January 31, 2024
To our clients and friends:
On January 22, the National Credit Union Administration issued a letter to credit union boards of directors and CEOs outlining its annual supervisory priorities and highlighting the areas it views as posing the highest risk to the credit union industry in 2024. Our Client Alert covers each of the identified priorities, discusses where the supervisory focus will be within each area this year, and identifies some ways for boards and management to get ahead before the next exam. Our Alert regarding the NCUA’s supervisory priorities is available here.
Luse Gorman routinely advises credit unions on compliance issues and regulatory questions, and counsels those institutions on the impacts of new developments at the federal and state level. To learn more about our firm and services, please visit our website.
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January 18, 2024
To our clients and friends:
Today we published Volume 1 of The Bankers’ Bulletin. You can find a copy of this volume of The Bankers’ Bulletin here.
This new publication from Luse Gorman covers regulatory and enforcement insights from our team related to recent developments in the banking industry, and provides our perspective on how those developments may impact your compliance obligations and your operations. The Bulletin will cover legislation, regulations, guidance, enforcement actions, court opinions, agency testimony, and other items of interest for national and state-chartered banks and thrifts. We plan to circulate it by email on the first Monday of every month.
If you have any questions related to any of the items covered in the Bulletin, please reach out to Brendan Clegg (bclegg@luselaw.com), Marc Levy (mlevy@luselaw.com), Agata Troy (atroy@luselaw.com), or your regular Firm contact. To learn more about our firm and services, please visit our website.
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