Publications Archive

Question: If we need to temporarily shut down one of our branches to treat for dangerous mold, do we need to give any kind of notice to our regulator?   Answer: At the federal level, there’s a specific exemption for temporary closings that are ...Read More

Question: I have a quick question related to Regulation D and reserve requirements. If we offer commercial escrow services to hold funds for two or more parties, are these funds held in escrow generally subject to Reg. D?   Answer: Yes, escrow funds are specifically included in the definition of ...Read More

Question: For examination purposes, should we be logging all changes to our website or just the ones related to compliance?   Answer: Since the bank’s website is generally considered an advertisement and sometimes contains disclosures required by federal regulations, the bank would want to ...Read More

By Jenny McCain In late April, the Board of Governors of the Federal Reserve System approved a notice of proposed rulemaking that would revise the Federal Reserve’s “control” rules under the Bank Holding Company Act of 1956 (Regulation Y). These rules that establish the ...Read More

The first line of last week’s Capitol Notes remains the same for this week’s edition: “The calendar giveth, and the calendar taketh away.”  But this time, the “calendar” in question is not the one that determines when the Legislature is or will be in ...Read More

by Chris Couch, McGlinchey Boards frequently report anxiety around data security, and question whether their policies and procedures are sufficient. With the average direct cost of a security incident approaching $4 million and the indirect, reputational costs beyond calculation, it’s easy to understand why. ...Read More

The calendar giveth, and the calendar taketh away. On Thursday, the fifth and seventh floors of the Alabama State House were abuzz over rumors that the end of the 2019 Regular Session was finally in sight. Legislators, if the rumors were true, were going ...Read More