The Consumer Financial Protection Bureau ("CFPB"), the FDIC and the Office of the Comptroller of Currency ("OCC") issued a joint enforcement action against a Pennsylvania bank for "unfair and deceptive practices in violation of Section 5 of the Federal Trade Commission Act." The regulatory agencies found that bank practices related to reconciling deposits failed to resolve discrepancies between the amount of funds deposited by customers and the amount encoded from the accompanying deposit slip. The regulatory agencies stated that the bank failed to notify customers when discrepancies were

SIFMA Managing Director Dave Oxner "debunked" the "five popular myths" utilized by a "small, but vocal, group of lawmakers and privacy interests" to oppose the Cyber Security Information Sharing Act ("CISA") of 2015. Mr. Oxner set forth the following as fact: (i) "CISA's definition of cyber threat indicators ("CTIs") is very limited" for sharing cyber threat information and rarely results in "any implication of an individual's behavioral, financial, or social information"; (ii) CISA does not authorize the government to surveil individuals, and monitoring can only be conducted on a company's

The SEC's request for an extension of the approved collection of information provided for in Rule 17Ad-15 under the Securities Exchange Act was published in the Federal Register. Rule 17Ad-15 requires approximately 429 transfer agents to establish written standards for the acceptance or rejection of guarantees of securities transfers from eligible guarantor institutions. Transfer agents are required to establish procedures to ensure that those standards are used by the transfer agent to determine whether to accept or reject guarantees from eligible guarantor institutions. Rule 17Ad-16 requires

ISDA's latest annual Margin Survey showed "a small decline in the total amount of collateral supporting non-cleared derivatives transactions in 2014, in part due to a continued shift to central clearing." ISDA stated that this shift has resulted in: (i) a significant increase of collateral supporting cleared transactions and (ii) a sharp growth in the number of client cleared collateral agreements, "as an increasing number of end users began clearing in response to regulatory changes." ISDA stated that its annual Margin Survey provides information about the use of collateral in the over-the

In an article titled "Considering the Cumulative Effects of Regulation," Director of the Regulatory Studies Center and Professor at George Washington University, Susan E. Dudley suggests that requiring agencies to analyze the expected impact of new regulatory requirements, while important, "may not account for the cumulative effect of regulations on society or specific sectors of the economy." Dudley argues that even if "individually justified," new regulatory requirements "may have cumulative effects imposing undue, unduly complex, or inconsistent burdens." The article addressed how the