December 3, 2019
To our clients and friends:
The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Financial Crimes Enforcement Network, in consultation with the Conference of State Bank Supervisors, issued a joint statement today clarifying the legal status of hemp and the relevant Bank Secrecy Act (BSA) requirements applicable when providing financial services to these customers (the “Joint Statement”).
Our Alert, which summarizes the key provisions of the Joint Statement, is available here.
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November 18, 2019
On October 29, 2019, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (the “Federal Agencies”) adopted a final rule to simplify the regulatory capital requirements for eligible community banks and holding companies that opt into the community bank leverage ratio framework (“CBLR framework”), as required by Section 201 of the Economic Growth, Relief and Consumer Protection Act of 2018. The final rule will be effective as of January 1, 2020.
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October 31, 2019
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September 26, 2019
To our clients and friends:
The U.S. House of Representatives approved its version of the SAFE Banking Act of 2019 yesterday. The legislation would create a safe-harbor for banks, thrift and credit unions to provide financial products and services to state-licensed cannabis businesses and their service providers.
The legislation also directs the federal banking regulators to jointly issue guidance on the legality of providing financial products and services to businesses that sell hemp, hemp-derived CBD and hemp-derived cannabinoid products.
The attached Alert summarizes the key provisions of the legislation.
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June 19, 2019
To our clients and friends:
The Securities and Exchange Commission recently proposed amendments to its definitions of “accelerated filer” and “large accelerated filer.” The attached newsletter provides a review of the proposed changes and discusses how those changes would affect public companies’ periodic reporting with the SEC.
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