WG Consulting held an early morning breakfast seminar at the Houston Junior League to discuss the Dodd-Frank Compliance landscape as it currently stands as is expected to shape out--and how that effects energy businesses of all sizes today.
May 13, 2015 Webinar
Presented by EDR & EBA
“The Dodd-Frank Act” is all over the news. It’s reportedly killing community banks, and will impact all of the banking members in this distribution in some capacity. In continuation of a February Environmental Bankers Association - Risk Management Call (EBA-RMC) John Rybak and Greg Lampe of BB&T Bank, and attorney Brad Merrill of Snell-Wilmer, will provide an explanation of what’s going on, notably with respect to Banking Vendor Management (“vetting the vendors”).
Since its passage in 2010, implementation and interpretation of the 2,323 page long Dodd-Frank Act has touched most every part of banking including how banks use vendors, particularly in the area of mortgages and consumer compliance. Five years later there remains substantial uncertainty as new rule making continues. During our call we will provide a summary of key regulatory areas every banker should be aware of in vendor management as well as some of the general results of Dodd-Frank and exposure for non-compliance.
This presentation serves as study notes for the e-learning material titled: "South African Hedge funds and international developments"
These notes focus on Dodd Frank and its Impact on the Hedge Fund Industry.
http://www.hedgefund-sa.co.za/dodd-frank
Dodd Frank Act 2015 Rule Implementation: Will The World End?Jillayne Schlicke
The Dodd Frank Act Rule Implementation of 2015 will bring another set of changes to the lending and escrow industries. Spoiler alert: The world will not end.
WG Consulting held an early morning breakfast seminar at the Houston Junior League to discuss the Dodd-Frank Compliance landscape as it currently stands as is expected to shape out--and how that effects energy businesses of all sizes today.
May 13, 2015 Webinar
Presented by EDR & EBA
“The Dodd-Frank Act” is all over the news. It’s reportedly killing community banks, and will impact all of the banking members in this distribution in some capacity. In continuation of a February Environmental Bankers Association - Risk Management Call (EBA-RMC) John Rybak and Greg Lampe of BB&T Bank, and attorney Brad Merrill of Snell-Wilmer, will provide an explanation of what’s going on, notably with respect to Banking Vendor Management (“vetting the vendors”).
Since its passage in 2010, implementation and interpretation of the 2,323 page long Dodd-Frank Act has touched most every part of banking including how banks use vendors, particularly in the area of mortgages and consumer compliance. Five years later there remains substantial uncertainty as new rule making continues. During our call we will provide a summary of key regulatory areas every banker should be aware of in vendor management as well as some of the general results of Dodd-Frank and exposure for non-compliance.
This presentation serves as study notes for the e-learning material titled: "South African Hedge funds and international developments"
These notes focus on Dodd Frank and its Impact on the Hedge Fund Industry.
http://www.hedgefund-sa.co.za/dodd-frank
Dodd Frank Act 2015 Rule Implementation: Will The World End?Jillayne Schlicke
The Dodd Frank Act Rule Implementation of 2015 will bring another set of changes to the lending and escrow industries. Spoiler alert: The world will not end.
Basel iii Compliance Professionals Association (BiiiCPA)
http://www.basel-iii-association.com
The Basel iii Compliance Professionals Association (BiiiCPA) is the largest association of Basel iii Professionals in the world. It is a business unit of the Basel ii Compliance Professionals Association (BCPA), which is also the largest association of Basel ii Professionals in the world.
Receive (at no cost) the New Member Orientation newsletters:
http://www.basel-iii-association.com/New_Member_Orientation_Newsletters.html
Subscribe to Receive (at no cost) Basel II / Basel III Related News, Alerts, Opportunities, Updates, our Monthly Newsletter and Limited Time Offers for our Basel II / Basel III Training and Certification Programs:
http://forms.aweber.com/form/42/1586130642.htm
Dodd-Frank's Impact on Regulatory ReportingHEXANIKA
We previously analyzed how Dodd-Frank and how the new regulations have impacted large banks as well as midsize and small banks. This time, we will look at how the law meant to address one issue (avoid a financial meltdown similar to 2008) might have created other challenges for banks – the most important one that of regulatory reporting:
FATCA: why is it so difficult even after so many years?HEXANIKA
Under this law, all non-U.S. Foreign Financial Institutions (FFI’s) are required to search their records for U.S. persons and to report the assets and identities of such persons to the U.S. Department of the Treasury. Read the detailed report here:
The Volcker Rule: Its Implications and AftereffectsHEXANIKA
The Volcker Rule is named after Paul A. Volcker, chairman of the Federal Reserve during the 1980s and an elder statesman of the financial world. He acted as an advisor for President Obama in 2008 and was instrumental in the passing and creation of the Rule. It aims to prevent large banks from engaging in speculative trading activity with the idea that important banks support the economy by lending to consumers and businesses. We briefly explain the Volcker Rule, the challenges it brings to banks and how they can be addressed:
Compendio sistematizado de regulaciones USA relevantes en materia de fraude corporativo, corrupción, compliance y eventual riesgo penal internacional (también, en varias de ellas, para empresas chilenas, o sus dueños y ejecutivos)
The Responsibilities of Banks, Sovereign Wealth Funds and Other Financial Ins...Larry Catá Backer
Extractive industries have been at center of CSR and environmental responsibilities debates at the national and international level. It has been noted that "The sector faces unique social and environmental challenges when operating in developing countries. Faced with these challenges, a number of Canadian companies are engaging in corporate social responsibility (CSR) initiatives, generally defined as the voluntary activities undertaken by a company to operate in an economically, socially and environmentally sustainable manner" (Building the Canadian Advantage: A Corporate Social Responsibility (CSR) Strategy for the Canadian International Extractive Sector). These generally involve direct compliance. Domestic law focuses on the law and regulatory frameworks of home and host states. Soft law focuses on national (to a small extent) and more generally in international framing mechanisms and indigenous law (national an international). In addition, private law also applies--to the extent that extractive enterprises build their own internal governance systems applicable through their production chains worldwide.
But increasing there is a need to think about indirect compliance: especially the responsibilities of financial institutions, suppliers, and upstream customers to gauge their conduct by the legal/normative compliance of the extractives enterprise itself.
This presentation focuses on financial institutions and their responsibilities with respect to the human rights responsibilities of their borrowers.
Winston & Strawn presented “Recent Legislation Impacting Dodd-Frank Requirements: What Financial Institution Directors Need to Know.” This webinar included a discussion of recent legislative changes to Dodd-Frank, what the FRB and OCC are focused on, other bank regulatory developments, and how these affect directors.
Changing Face of Chapter 11 January 2014Ted Stenger
Finance and Legal experts on the changes in Chapter 11 including the end of Mega case, turnarounds in Chapter 11 are dead and the rush to get in and out of Chapter 11
Unlocking the Value of Regulatory Compliance to Advance Financial Planning &...Proformative, Inc.
Call reporting, DFAST, CCAR - the amount of time and energy spent by banks to comply with cumbersome banking regulations is painful at best. You can turn this process into an advantage for your company by leveraging current advances in technology to cost-effectively streamline compliance with regulatory requirements and deliver more advanced planning and analysis that fuels company growth.
US/ Canada cross-border tax planning could be impacted by the recent finalization of Section 385 regulations by the IRS and Treasury Department. Because most of these new rules apply with an effective date reaching back to April 5, 2016, it is imperative that Canadian companies with U.S. activities assess their potential impact and develop a strategy for managing their exposure to these rules.
Basel iii Compliance Professionals Association (BiiiCPA)
http://www.basel-iii-association.com
The Basel iii Compliance Professionals Association (BiiiCPA) is the largest association of Basel iii Professionals in the world. It is a business unit of the Basel ii Compliance Professionals Association (BCPA), which is also the largest association of Basel ii Professionals in the world.
Receive (at no cost) the New Member Orientation newsletters:
http://www.basel-iii-association.com/New_Member_Orientation_Newsletters.html
Subscribe to Receive (at no cost) Basel II / Basel III Related News, Alerts, Opportunities, Updates, our Monthly Newsletter and Limited Time Offers for our Basel II / Basel III Training and Certification Programs:
http://forms.aweber.com/form/42/1586130642.htm
Dodd-Frank's Impact on Regulatory ReportingHEXANIKA
We previously analyzed how Dodd-Frank and how the new regulations have impacted large banks as well as midsize and small banks. This time, we will look at how the law meant to address one issue (avoid a financial meltdown similar to 2008) might have created other challenges for banks – the most important one that of regulatory reporting:
FATCA: why is it so difficult even after so many years?HEXANIKA
Under this law, all non-U.S. Foreign Financial Institutions (FFI’s) are required to search their records for U.S. persons and to report the assets and identities of such persons to the U.S. Department of the Treasury. Read the detailed report here:
The Volcker Rule: Its Implications and AftereffectsHEXANIKA
The Volcker Rule is named after Paul A. Volcker, chairman of the Federal Reserve during the 1980s and an elder statesman of the financial world. He acted as an advisor for President Obama in 2008 and was instrumental in the passing and creation of the Rule. It aims to prevent large banks from engaging in speculative trading activity with the idea that important banks support the economy by lending to consumers and businesses. We briefly explain the Volcker Rule, the challenges it brings to banks and how they can be addressed:
Compendio sistematizado de regulaciones USA relevantes en materia de fraude corporativo, corrupción, compliance y eventual riesgo penal internacional (también, en varias de ellas, para empresas chilenas, o sus dueños y ejecutivos)
The Responsibilities of Banks, Sovereign Wealth Funds and Other Financial Ins...Larry Catá Backer
Extractive industries have been at center of CSR and environmental responsibilities debates at the national and international level. It has been noted that "The sector faces unique social and environmental challenges when operating in developing countries. Faced with these challenges, a number of Canadian companies are engaging in corporate social responsibility (CSR) initiatives, generally defined as the voluntary activities undertaken by a company to operate in an economically, socially and environmentally sustainable manner" (Building the Canadian Advantage: A Corporate Social Responsibility (CSR) Strategy for the Canadian International Extractive Sector). These generally involve direct compliance. Domestic law focuses on the law and regulatory frameworks of home and host states. Soft law focuses on national (to a small extent) and more generally in international framing mechanisms and indigenous law (national an international). In addition, private law also applies--to the extent that extractive enterprises build their own internal governance systems applicable through their production chains worldwide.
But increasing there is a need to think about indirect compliance: especially the responsibilities of financial institutions, suppliers, and upstream customers to gauge their conduct by the legal/normative compliance of the extractives enterprise itself.
This presentation focuses on financial institutions and their responsibilities with respect to the human rights responsibilities of their borrowers.
Winston & Strawn presented “Recent Legislation Impacting Dodd-Frank Requirements: What Financial Institution Directors Need to Know.” This webinar included a discussion of recent legislative changes to Dodd-Frank, what the FRB and OCC are focused on, other bank regulatory developments, and how these affect directors.
Changing Face of Chapter 11 January 2014Ted Stenger
Finance and Legal experts on the changes in Chapter 11 including the end of Mega case, turnarounds in Chapter 11 are dead and the rush to get in and out of Chapter 11
Unlocking the Value of Regulatory Compliance to Advance Financial Planning &...Proformative, Inc.
Call reporting, DFAST, CCAR - the amount of time and energy spent by banks to comply with cumbersome banking regulations is painful at best. You can turn this process into an advantage for your company by leveraging current advances in technology to cost-effectively streamline compliance with regulatory requirements and deliver more advanced planning and analysis that fuels company growth.
US/ Canada cross-border tax planning could be impacted by the recent finalization of Section 385 regulations by the IRS and Treasury Department. Because most of these new rules apply with an effective date reaching back to April 5, 2016, it is imperative that Canadian companies with U.S. activities assess their potential impact and develop a strategy for managing their exposure to these rules.
Week 7 - Legal Issues in Blockchain and CryptocurrenciesRoger Royse
Instructor: Roger Royse, Founder of Royse Law Firm
Course Title: The Business Basics of Blockchain, Cryptocurrencies, and Tokens
Location: Stanford Continuing Studies
Week: 7 (of 7)
The seventh session will examine legal issues in blockchain applications. We will discuss the legal structure of an initial coin or security coin offering (ICO) in the US and globally, including the rules governing the sale of securities in the US. We will overview patent and intellectual property (IP) issues in blockchain and licensing agreements that provide protection to inventors while making resources available for open innovation.
Dodd-Frank Compliance and Technology Summer Meeting 2013Jeffrey C.Y. Li
Atlas Communications Technology recently co-sponsored the Dodd-Frank Compliance and Technology Summer Meeting. The presentation was an introduction to the complexities of the Dodd-Frank Wall Street Reform and Consumer Protection Act, what firms need to do to bring themselves into compliance, and the technology that can help enterprises meet the stringent demands of the act.
For more information about this conference, or to learn about our Fall meeting in September featuring one of the authors of the act, Congressman Jim Himes, please call 1-855-Dodd Frank (1-855-363-3372) for any questions, or if you wish to talk to one of our presenters today to talk about taking the next steps towards Dodd-Frank Compliance
Atlas Presentation 2013 07-09 dodd-frank summer meeting v1-0 (for online)
What is SEC?
The U.S. Securities and Exchange Commission (SEC) oversees the key participants in the securities world.
Concerned with promoting disclosure of important market information, maintaining fair dealing, and protecting against fraud.
Responsibilities include:
Interpret and enforce federal securities laws
Issue new rules and amend existing rules
Oversee inspection of securities firms, brokers, investment advisers and ratings agencies
Oversee private regulatory organizations in securities, accounting, auditing fields
Coordinate U.S. securities regulation with federal, state, and foreign authorities
SEC Organization:
Division of Corporate Finance:Reviews documents required to be filed with the Commission
Division of Trading: Assists in maintaining fair, orderly and efficient markets.
Division of Investment Management: Maintains oversight of America’s $26T investment management industry
Division of Enforcement: Recommends commencement of investigations of SEC law violations
Division of Economic and Risk Analysis: Integrates robust economic analysis and data analytics
Laws Governing SEC:
Securities Act of 1933
Securities Exchange Act of 1934
Trust Indenture Act of 1939
Investment Company Act of 1940
Investment Advisers Act of 1940
Sarbanes-Oxley Act of 2002
Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
Jumpstart Our Business Startups Act of 2012
SEC Reports:
8k - A report of unscheduled material events or corporate changes at a company that could be of importance to the shareholders or SEC
10k - Comprehensive summary report of a company's performance. Submitted annually to the SEC
10Q - A comprehensive report of a company's performance that must be submitted quarterly by all public companies to SEC. In10-Q, firms are required to disclose relevant information regarding their financial position.
18K - Use to update the SEC and investors regarding the status of a domestically traded foreign security and its issuer.
20F - A form issued by the SEC that must be submitted by all "foreign private issuers" that have listed equity shares on exchanges in the U.S.
SEC Investigations:
Can be triggered in many ways
Investigation is not the same as prosecution
Investigations involve fact finding and are usually not public
During an investigation, neither the staff nor the Commission makes any determination of wrongdoing
Following investigation, SEC staff present findings to the Commission
Commission can authorize the staff to file a case in federal court or bring an administrative action.
Orderly Liquidation Authority under Dodd-FrankSimon Lacey
This is a presentation I prepared while at Georgetown University Law Center in 2001 on Orderly Liquidation Authority under the then newly enacted Dodd-Frank Act.
This presentation highlights a number of the most important policy issues on which MFA remains focused. Issues covered in this document include, among others:
• Promoting non-discriminatory tax policy.
• Taxation of partnerships
• CFTC reauthorization
• Regulating systemic risk
• Protecting investors
• Promoting the stability of markets through central clearing of derivatives
• Capital formation and the JOBS Act implementation
• Equity market structure
Financial Sector Responsibility for Human Rights Conduct of Borrowers: What W...Larry Catá Backer
Extractive industries have been at center of CSR and environmental responsibilities debates at the national and international level
The sector faces unique social and environmental challenges when operating in developing countries. Faced with these challenges, a number of Canadian companies are engaging in corporate social responsibility (CSR) initiatives, generally defined as the voluntary activities undertaken by a company to operate in an economically, socially and environmentally sustainable manner. Building the Canadian Advantage: A Corporate Social Responsibility (CSR) Strategy for the Canadian International Extractive Sector
To what extent are financial institutions responsible for the human rights breaches of their borrowers?
“While the obligation for the protection of human rights lies with the state, IFIs and their member states also have responsibilities to ensure that activities they support do not cause, or contribute to, human rights abuses by putting in place adequate safeguards.” Statement of Global Initiative for Economic, Social and Cultural Rights to UN Human Rights Council. How might these obligations constrain borrowers?
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𝐓𝐉 𝐂𝐨𝐦𝐬 (𝐓𝐉 𝐂𝐨𝐦𝐦𝐮𝐧𝐢𝐜𝐚𝐭𝐢𝐨𝐧𝐬) is a professional event agency that includes experts in the event-organizing market in Vietnam, Korea, and ASEAN countries. We provide unlimited types of events from Music concerts, Fan meetings, and Culture festivals to Corporate events, Internal company events, Golf tournaments, MICE events, and Exhibitions.
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"𝐄𝐯𝐞𝐫𝐲 𝐞𝐯𝐞𝐧𝐭 𝐢𝐬 𝐚 𝐬𝐭𝐨𝐫𝐲, 𝐚 𝐬𝐩𝐞𝐜𝐢𝐚𝐥 𝐣𝐨𝐮𝐫𝐧𝐞𝐲. 𝐖𝐞 𝐚𝐥𝐰𝐚𝐲𝐬 𝐛𝐞𝐥𝐢𝐞𝐯𝐞 𝐭𝐡𝐚𝐭 𝐬𝐡𝐨𝐫𝐭𝐥𝐲 𝐲𝐨𝐮 𝐰𝐢𝐥𝐥 𝐛𝐞 𝐚 𝐩𝐚𝐫𝐭 𝐨𝐟 𝐨𝐮𝐫 𝐬𝐭𝐨𝐫𝐢𝐞𝐬."
Improving profitability for small businessBen Wann
In this comprehensive presentation, we will explore strategies and practical tips for enhancing profitability in small businesses. Tailored to meet the unique challenges faced by small enterprises, this session covers various aspects that directly impact the bottom line. Attendees will learn how to optimize operational efficiency, manage expenses, and increase revenue through innovative marketing and customer engagement techniques.
Affordable Stationery Printing Services in Jaipur | Navpack n PrintNavpack & Print
Looking for professional printing services in Jaipur? Navpack n Print offers high-quality and affordable stationery printing for all your business needs. Stand out with custom stationery designs and fast turnaround times. Contact us today for a quote!
Attending a job Interview for B1 and B2 Englsih learnersErika906060
It is a sample of an interview for a business english class for pre-intermediate and intermediate english students with emphasis on the speking ability.
What is the TDS Return Filing Due Date for FY 2024-25.pdfseoforlegalpillers
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Cracking the Workplace Discipline Code Main.pptxWorkforce Group
Cultivating and maintaining discipline within teams is a critical differentiator for successful organisations.
Forward-thinking leaders and business managers understand the impact that discipline has on organisational success. A disciplined workforce operates with clarity, focus, and a shared understanding of expectations, ultimately driving better results, optimising productivity, and facilitating seamless collaboration.
Although discipline is not a one-size-fits-all approach, it can help create a work environment that encourages personal growth and accountability rather than solely relying on punitive measures.
In this deck, you will learn the significance of workplace discipline for organisational success. You’ll also learn
• Four (4) workplace discipline methods you should consider
• The best and most practical approach to implementing workplace discipline.
• Three (3) key tips to maintain a disciplined workplace.
RMD24 | Retail media: hoe zet je dit in als je geen AH of Unilever bent? Heid...BBPMedia1
Grote partijen zijn al een tijdje onderweg met retail media. Ondertussen worden in dit domein ook de kansen zichtbaar voor andere spelers in de markt. Maar met die kansen ontstaan ook vragen: Zelf retail media worden of erop adverteren? In welke fase van de funnel past het en hoe integreer je het in een mediaplan? Wat is nu precies het verschil met marketplaces en Programmatic ads? In dit half uur beslechten we de dilemma's en krijg je antwoorden op wanneer het voor jou tijd is om de volgende stap te zetten.
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Falcon stands out as a top-tier P2P Invoice Discounting platform in India, bridging esteemed blue-chip companies and eager investors. Our goal is to transform the investment landscape in India by establishing a comprehensive destination for borrowers and investors with diverse profiles and needs, all while minimizing risk. What sets Falcon apart is the elimination of intermediaries such as commercial banks and depository institutions, allowing investors to enjoy higher yields.
1. Automation. Collaboration. Integration.
The Dodd-Frank Effect on
Information Management
Today’s Speakers: Katey Wood Jacquie Safran
Analyst Director of Sales
ESG Exterro, Inc.
Shannon Smith John Isaza
Paralegal Partner
Rabobank Howett Isaza Law Group LLP
2. Today’s Speakers
Shannon Smith
Paralegal
Rabobank Group
Shannon Smith has worked as a paralegal in Rabobank Nederland, New York
Branch’s Legal Department since 2005. Her role includes litigation support and
she has been instrumental in implementing an e-discovery readiness program
for the bank.
Shannon received her BA from Hunter College in New York and will be
attending law school in the fall.
3. Today’s Speakers
John Isaza
Partner
Howett Isaza Law Group LLP
John Isaza, Esq. is a California-based attorney and partner of Howett Isaza Law Group,
LLP (HiL). Mr. Isaza is widely recognized as one of the country’s foremost experts on
electronic information governance, records management, and e-discovery
preparedness. His clients include some of the most highly regulated Fortune 500
companies.
Prior to forming HiL, Mr. Isaza served as in-house General Counsel to a publicly traded
medical device manufacturer now owned by Abbott Laboratories. At present, he is an
active speaker in the ARMA, AIIM, ABA and IT compliance circuits. Mr. Isaza chaired the
Chicago Program Committee for ARMA’s 2005 international conference; he is a
member of ARMA’s Electronic Discovery Advisory Group and the GARP® Metrics Task
Force and he has served on the Board of Directors of ARMA International. Mr. Isaza co-
authored a book entitled 7 Steps for Legal Holds of ESI & Other Documents released in
July 2009.
4. Today’s Speakers
Katey Wood
Analyst
ESG
Katey Wood joined ESG in 2011 covering Information Management, including e-
discovery, enterprise search, content management, archiving, and records
management. Prior to ESG, she covered e-discovery, enterprise search, information
governance, and text analytics as an analyst at the 451 Group. She also worked
previously on the rollout of New York State’s Statewide Access Child Welfare
Information System (SACWIS), a Federally-funded data warehousing and BI
initiative.
Katey holds a double Masters in Information Systems and Library Science from
Drexel University, and a BA from Wellesley College, and has studied at NYU’s Arthur
L. Carter Institute of Journalism in Cultural Criticism and Reporting.
5. Today’s Speakers
Jacquie Safran
Director of Sales
Exterro, Inc.
Jacqueline Safran brings more than 12 years of sales and marketing experience,
and nine years of experience focused on providing corporations and law firms with
e-discovery and information management technology.
Safran has successfully provided solutions covering every phase of the Electronic
Discovery Reference Model, and excels in understanding organizations' business
needs and providing clients with technology that best meets their requirements.
6. Todays’ Agenda
Overview of Dodd-Frank
• Brief overview
• Who is affected
• Status of agency responses
• Impact on non-financial companies
Impact on Information Governance Policies
• Establishing a strong information governance policy
• A unified approach to mission critical functions
New Record Keeping Requirements
• Proposed CFTC rules
• Creating an airtight retention and disposition policy
Impact on Legal Holds
• Trigger Events
• Crafting a defensible legal hold
7. Dodd-Frank Act Overview
Dodd-Frank Wall Street Reform and Consumer
Protection Act:
To promote the financial stability of the United
States by improving accountability and
transparency in the financial system, to end ‘too
big to fail’, to protect the American taxpayer by
ending bailouts, to protect consumers from
abusive financial services practices, and for
other purposes.
8. Status of Agency Responses
Soft Metrics re: Recordkeeping and the Act:
848- Page Document “Record” Mentioned “Recordkeeping” Only 1 supplemental
198 times mentioned 34 times comment
* Earliest deadline for regulators is 7/11, so too early to tell
* Supplemental comment provided by Federal Reserve (Official Staff
Interpretation)
• Reg Z, TILA, Part 226
• Nothing substantive re: recordkeeping
9. Status of Agency Responses
Title I, focusing on financial stability, creates…
• Financial Stability Oversight Council - tasked
with oversight of non-bank financial companies
• Office of Financial Research
• Both given authority to promulgate regulations
• No final rules reported at this time
10. Status of Agency Responses
Title I tasks FDIC (the “Corporation”) as follows:
• Unless otherwise required by applicable Federal law or
court order, the Corporation may not, at any time,
destroy any records that are subject to clause (i)
[recordkeeping requirements].
• The terms ‘‘records’’ and ‘‘records of a covered
financial company’’ mean any document, book, paper,
map, photograph, microfiche, microfilm, computer or
electronically-created record generated or maintained
by the covered financial company in the course of and
necessary to its transaction of business.
11. Status of Agency Responses
Title II, focusing on Liquidations, provides for new
recordkeeping requirements, and ostensibly tasks FDIC
with coming up with more:
• Agencies asked to jointly prescribe regulations
requiring that financial companies maintain such
records with respect to qualified financial contracts
(including market valuations)
• The Federal primary financial regulatory agencies
shall prescribe joint final or interim final
regulations not later than 24 months after the date
of enactment of this Act.
• No final rules reported at this time.
12. Status of Agency Responses
Title III, delegates powers to:
• Comptroller of the Currency
• FDIC (the “Corporation”)
• Federal Reserve’s Board of Governors
Title IV, Regulates Advisers to Hedge Funds and Others
No final rules reported at this time re: additional
recordkeeping requirements, other than those mentioned in
the Act
13. Status of Agency Responses
Title V, focusing on insurance sector, creates:
• Federal Insurance Office
• Another prospect for later regulations
• No final rules reported at this time
14. Status of Agency Responses
Title VI, imposes improvements to Regulation of Banks
and Savings Association Holding Companies and
Depository Institutions
• “Each supervised securities holding company and each affiliate
of a supervised securities holding company shall make and keep
for periods determined by the Board of Governors such records, furnish copies
of such records, and make such reports, as the Board of Governors determines
to be necessary or appropriate to carry out this section, to prevent evasions
thereof, and to monitor compliance by the supervised securities holding
company or affiliate with applicable provisions of law”
• “AVAILABILITY—A supervised securities holding company or an affiliate of a
supervised securities holding company shall promptly provide to the Board of
Governors, at the request of the Board of Governors, any report...”
• Availability is one of the GARP® Principles
15. Status of Agency Responses
Title VII, Wall Street Transparency and Accountability:
• “The Commodity Futures Trading Commission and the
Securities and Exchange Commission, in consultation
with the Board of Governors *Federal Reserve’s+, shall
engage in joint rulemaking to jointly adopt a rule or
rules governing books and records regarding security-
based swap agreements, including daily trading records,
for swap dealers, major swap participants, security-
based swap dealers, and security-based swap
participants.”
• No additional “final” recordkeeping rules reported at
this time
16. Status of Agency Responses
Title IX, Investor Protections and amendments to
securities regulations
• Affecting 1933 and 1934 Acts, including Investment
Advisers Act
• No significant or apparent changes to length of retention
requirements
• However, broad authority to impose more retention and
reporting requirements
• No additional “final” recordkeeping rules reported at
this time
17. Status of Agency Responses
Title X, establishes Bureau of Consumer Financial
Protection
• The Bureau shall seek to implement and, where
applicable, enforce Federal consumer financial law
consistently for the purpose of ensuring that all
consumers have access to markets for consumer financial
products and services and that markets for consumer
financial products and services are fair, transparent, and
competitive
• No final recordkeeping rules reported at this time
18. Status of Agency Responses
Title XIV, calls for Mortgage Reform and Anti-Predatory
Lending
• Regulate loan originations
• Minimum standards for mortgages
• Regulates high cost mortgages
• Establishes Office of Housing Council
• Regulates mortgage servicing
• Regulates appraisal activities
• No final recordkeeping rules reported at this time
19. Status of Agency Responses
Title XV, imposes:
• Restrictions on use of US funds for foreign governments
• Taxpayer protections
• Dealings with conflicts minerals (e.g., blood diamonds)
• Coal and mine safety
20. Impact on Non-Financial Companies
A number of provisions are included on corporate governance and executive
compensation which apply to all public companies without regard to industry
• Clawback requirement for incentive compensation paid to executives
based on misstated financial statements
• Increased executive compensation disclosures
Consumer Finance Operations
• CFPB will serve as regulatory authority over all consumer financial
products and services unless clearly exempted (charities, auto dealers
and professional services firms). CFPB will have the authority to regulate
covered persons offering consumer financial products or services.
• Will be subjected to considerable regulatory burdens that will include
extensive new record keeping and reporting requirements
21. Impact on Non-Financial Companies
The Whistleblower Provision…
Will apply to any company with a potential
securities or commodities law violation
May apply to violations of FCPA
Companies must be prepared to prove they
are in compliance
22. Impact on Information Governance Policies
Financial services firms are already struggling to
manage their vast data stores in a way that
satisfies existing privacy and regulatory
requirements
• The Dodd-Frank Act mandates a number of significant
changes that include improving regulatory reporting
capabilities
• Changes need to be executed in a coordinated fashion
across a number of business units
• Will require a well managed information flow across
different teams and stakeholders
23. Establishing a Strong Information
Governance Policy
Where to Start…
Form a Working Group Perform a gap analysis
• To improve • Determine groups
coordination among affected by proposed
the various segments legislation
of the organization • Determine processes in
• Clarify issues, place and those
formulate strategies, needed
and develop action
plans
24. Establishing a Strong Information
Governance Policy
The GARP® Principles:
A CCOUNTABILITY
T RANSPARENCY
I NTEGRITY
P ROTECTION
C OMPLIANCE
A VAILABILITY
R ETENTION
D ISPOSITION
25. A Unified Approach to Mission
Critical Functions
The shift to consolidate…
• The Act will boost regulatory requests
• Legal action against wall street firms such as Goldman Sachs illustrate
the need to be able to respond to an increase in both civil and criminal
legal inquiries
• New whistleblower provisions with increased monetary motivation will
likely spur whistleblower reporting leading to additional independent
internal investigations
Corporate legal departments at financial institutions should take a unified
approach to internal investigations, e-discovery, audit and compliance.
A shift to consolidate these areas will help drive efficiency, cost
effectiveness, and break down departmental silos.
27. New Record Keeping Requirements
proposed CFTC rules require companies to
maintain full and complete transaction and
position information for all swap activities.
• Records must be maintained in a “manner that is
identifiable and searchable by transaction and by
counterparty.”
• Require the retention of basic business records, including
corporate governance minutes, organizational charts, and
audit/compliance documentation.
• The Act’s data retention requirements even extend to
certain financial records (such as information related to
cash positions or forward transactions used to hedge),
records of complaints against personnel, and marketing
materials.
28. New Record Keeping Requirements
Have an air-tight retention and disposition policy
• Know your data, where it lives, who has access, its retention
requirements
• Make sure data is accessible to respond to requests
• Retain only what you need – regulators can collect data outside
of formalized retention requirements
• Delete de-commissioned data defensibly and thoroughly
• Coordinate routine retention and deletion with legal hold
preservation requirements to prevent spoliation
• Self-audit to gauge performance and ongoing-readiness
29. Impact on Legal Holds
The confluence of increasing data volumes along with expectations of
increased regulatory oversight and actions underscores the importance of
sound enterprise wide information retention and disposition programs.
This program, in combination with formalized legal hold protocols, is a
critical line of defense during a litigation event.
Close coordination Align information risk
Treat legal holds as an among key management and
enterprise process stakeholders — compliance objectives
rather than a legal corporate counsel, with your information
department task compliance officers, retention and legal
and IT managers. hold program
30. Developing a Strong Legal Hold Process
1. Trigger Event Preservation Not Required
2. Analyze Duty NO
To Preserve
YES
3. Define Scope
4. Implement
Hold Implementation / Oversight / Training /
Audit / Tracking / Legal Hold Releases
5. Enforce &
Examine
6. Modify
7. Monitor &
Remove
31. Crafting a defensible legal hold
What to communicate in the hold
why the recipient of the hold was identified
in laymen's terms provide information about the
preservation requirement, including relevant date ranges
explicit instructions for preservation efforts that must be
taken
the consequences of failing to comply with the hold
the contact information for whomever they can call with
questions
that they must affirmatively acknowledge their intent to
comply with the requirements outlined in the hold
32. Crafting a defensible legal hold
Ongoing Compliance
Policy to reassess the sufficiency of preservation
efforts as litigation progresses.
Process to evaluate the sufficiency of the notice in
light of any changes in scope or subject of the
litigation.
Process to modify and re-issue the hold.
Process to remind custodians of their preservation
obligations.
Policy and process to notify custodians of release and
disposition
Process to communicate requirements relating to
terminated employees to appropriate IT and HR
personnel.
33. Key Take-Aways
Some regulations have yet to be written, but financial institutions and
corporations who may be subject to the Act need to stay ahead of
impending rules
Keys to success
• Auditable processes and content
• Flexibility to adapt to these and other new regulations
• Consistent and timely management and disposition of documents
• A unified approach to internal investigations, e-discovery, audit and
compliance
• Use technology solutions to drive transparency, automation, and
workflow management
• Align information risk management and compliance objectives with
your information retention and legal hold program