Welcome to Goodwin's Financial Services News Roundup. Our newsletter highlights important legal, regulatory, and business developments related to financial services and banking.
In this issue
- Acting FDIC Chairman Expresses Support for Enhancing Flexibility of Customer Identification Program Requirements
- FRB Releases the Hypothetical Scenarios for Its Annual Stress Test and Exploratory Analysis
1 Acting FDIC Chairman Expresses Support for Enhancing Flexibility of Customer Identification Program Requirements
On February 7, the Federal Deposit Insurance Corporation (FDIC) Acting Chairman Travis Hill sent a letter to the Financial Crimes Enforcement Network (FinCEN) in support of enhancing the flexibility of Customer Identification Program (CIP) requirements for bank-fintech partnerships – specifically, to allow fintechs to satisfy their CIP obligations by obtaining the last four digits of their customers' social security or tax identification numbers and, with their customers' permission, obtaining the rest of the number from a third-party source, such as a credit bureau. The Acting Chairman also requested that FinCEN work to align CIP requirements with the reality of bank-fintech relationships more broadly.
2 FRB Releases the Hypothetical Scenarios for Its Annual Stress Test and Exploratory Analysis
On February 5, the Board of Governors of the Federal Reserve System (FRB) released the hypothetical scenarios for its annual stress test, as well as two hypothetical elements assessing a wider range of risks through its "exploratory analysis" of the banking system. The annual stress test evaluates the resilience of large banks under two-year hypothetical recession scenarios, helping ensure that large banks can lend to households and businesses even in severe economic downturns. The FRB will publish aggregate results of these tests in June 2025. The FRB also intends to begin the public comment process this year on comprehensive changes to the stress test to reduce volatility of results and improve model transparency.
Check Out Goodwin's Latest Industry Insights
Goodwin in the News: CFPB's Closure Not 'A Free Pass' For Financial Compliance
Goodwin Partner Kim Holzel weighs in on Consumer Financial Protection Bureau (CFPB)'s pause and its implications for financial institutions. To read the full article, click here.
New Client Alert: Non-financial Misconduct and Culture: A Reminder for FCA-Regulated Firms in the UK
Firm culture remains a key topic on the Financial Conduct Authority's (FCA's) radar this year. In a previous alert, we discussed the FCA's proposals for all FCA-authorised firms to better integrate non-financial misconduct (NFM) considerations into their senior manager and certification regime (SMCR), including rules for staff fitness and propriety assessments, the FCA Conduct Rules, and threshold conditions for firms. To read more, click here.
New Client Alert: FINRA Publishes 2025 Annual Regulatory Oversight Report
On January 28, the Financial Industry Regulatory Authority (FINRA) published its 2025 Annual Regulatory Oversight Report (the Report) as "an up-to-date, evolving resource or library of information for firms" that highlights specific industry trends, new developments and findings, and effective firm practices. The Report builds on the 2024 Report, draws on findings by FINRA's Member Supervision, Market Regulation, and Enforcement programs, and can serve as a roadmap firms can use to focus on new developments and bolster their compliance programs throughout the year. To read the full alert, click here.
New Directions: The Trump
Administration
Strategic insights and guidance for businesses navigating shifts
in US policy and regulation.
Corporate Transparency Act (CTA) Resource
Center
Go-to resource and compliance toolkit.
Fintech Flash
The latest news and developments for the rapidly evolving fintech
industry – which often can change in a flash.
Bank Failure Knowledge Center
Visit our knowledge center for timely updates and analysis on
important developments related to bank failures.
Consumer Finance Insights
(CFI) Blog
The latest on consumer finance regulation, litigation, and
enforcement.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
