FinCEN Ruling on Identifiers in Beneficial Ownership Reporting

Earlier this week on November 7, 2023, FinCEN issued a Final Rule on the use of FinCEN identifiers in Beneficial Ownership information reporting after commenters raised concerns that the previously proposed language could actually obscure the identities of beneficial owners. The Final Rule provides clear criteria on the use and reporting of an entity’s FinCEN identifier. What is a FinCEN identifier? A “FinCEN identifier” is a unique identifying number that FinCEN will issue to an […]

Highlights from CRA Modernization Final Ruling

Last week, the Federal Reserve, FDIC, and Office of the Comptroller of the Currency (OCC) released the final rule for CRA Modernization. We are working hard behind the scenes to digest the nearly 1,500-page document, but while we’re working through that, here are a few highlights and elements of the law you should keep in mind as you begin to make a plan for compliance. Highlights of CRA Modernization CRA Modernization’s final ruling includes several […]

CRA Modernization Final Rule

Earlier today, The Office of the Comptroller of the Currency (OCC), the Federal Reserve Board, and the Federal Deposit Insurance Corporation (FDIC), issued a final rule to strengthen and modernize regulations implementing the Community Reinvestment Act (CRA). The CRA is designed to ensure federally insured banks meet the credit needs of the communities in which they do business, especially low- and moderate-income (LMI) communities.  The press release announcing the CRA Modernization’s final rule emphasizes that […]