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So Long, Summer
September 1, 2022

We say it every year: how did the summer go by so quickly? Well, it has, and as we approach Labor Day in the United States, we hope all of our readers in the U.S. and Europe can squeeze in a few more summer highlights before we all buckle in for what will likely be a busy September.

Have a great holiday weekend. 

Daniel Meade and Michael Sholem
Co-Editors, Cabinet News and Views

Partner | Financial Regulation
Partner | Financial Regulation

On August 18, the Federal Deposit Insurance Corporation issued Financial Institutions Letter 40-2022, which provided supervisory guidance for state non-member banks and multiple non-sufficient funds fees. The FDIC stated that it is issuing the guidance because of its observations in consumer compliance exams where consumers are charged multiple NSF fees for the same transaction when a merchant resubmits the transaction for payment. The FDIC has also observed that some institutions’ disclosures did not adequately describe the institution’s re-presentment practice. 

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Partner | Financial Regulation

The FBI’s August 29 Public Service Announcement warns the public (i.e., investors) about smart contract vulnerabilities on DeFi platforms.

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Partner | Financial Regulation

The DOJ recently published an opinion from the Office of Legal Counsel regarding the FDIC Board. The OLC opinion concluded that “the Chairperson of the FDIC Board does not have the authority to prevent a majority of the Board from presenting items to the Board for a vote and decision.”

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Partner | Financial Services

On August 19, the European Securities and Markets Authority announced the publication of its response to a consultation on the European Commission’s proposals to amend the regime for the provision of “third country” (meaning non-EU) benchmarks into the EU under the Benchmarks Regulation. The Commission’s consultation, which concluded on August 12, 2022, asked for views on whether the rules applicable to the use of benchmarks administered in a third country, which will fully enter into application in January 2024, are fit for purpose and if not, how should the BMR’s third country regime be amended.

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Senior Counsel
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