July 2023

On July 26, the Securities and Exchange Commission (SEC) adopted, by a 3-2 margin, a final rule to require more immediate disclosure of material cybersecurity incidents by public companies. In addition, the final rule requires annual disclosure of material information regarding a public company’s cybersecurity risk management strategy and cybersecurity governance.…

On July 28, the Board of Governors of the Federal Reserve System (Federal Reserve), Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, and the National Credit Union Administration (NCUA) (collectively, the agencies) issued an addendum to the agencies’ joint policy statement on funding and liquidity risk management, which advises depository institutions to…

On July 27, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a joint notice of proposed rulemaking that would revise the capital requirements applicable to large banking organizations (those with $100 billion or more in total…

In this episode of Payments Pros, Josh McBeain welcomes his colleague Andrew Thurmond to discuss residential solar projects as well as the financing and payment options that are available for these types of projects.…

Please join Troutman Pepper Partner Chris Willis and his colleague Kim Phan as they discuss the new California Privacy Rights Act (CPRA) and the creation of the California Privacy Protection Agency (CPPA), California’s first state agency focused exclusively on privacy. They also dive into the CPPA’s recent amendments to the California Consumer Privacy Act (CCPA),…

Today, the Federal Deposit Insurance Corporation (FDIC) issued a letter to financial institutions (FIL-37-2023) regarding the proper way to report estimated uninsured deposits in accordance with the instructions to the Consolidated Reports of Condition and Income (Call Report). FIL-37-2023 does not impact institutions with less than $1 billion in total assets that do not report…

CPRA Regulations Delayed. On June 29, 2023, two days before enforcement of the California Consumer Privacy Act (CCPA) was to begin, a Sacramento Superior Court issued a temporary injunction, enjoining enforcement of newly promulgated regulations under the California Privacy Rights Act (CPRA), which amended the CCPA earlier this year. The new regulations were promulgated and…

In March , the Court of Appeals for the Second Circuit requested that the Securities and Exchange Commission (SEC) submit a brief on whether a syndicated term loan qualifies as a “security.” The brief was highly anticipated after the SEC requested multiple extensions to submit. However, on July 18, the SEC relayed to the court…

On July 18, Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Large Bank Supervision Greg Coleman testified on OCC supervision of climate-related financial risks before the U.S. House of Representatives’ Committee on Financial Services’ Subcommittee on Financial Institutions and Monetary Policy.…