In an interagency statement, the Federal Reserve Board, FDIC, National Credit Union Administration, Office of the Comptroller of the Currency and FinCEN (collectively, the "agencies") addressed instances in which banks may share resources collaboratively in order to manage their Bank Secrecy Act ("BSA") and anti-money laundering ("AML") obligations. The agencies stated that collaborative arrangements are most suitable for community banks, which maintain "less complex operations and lower risk profiles for money laundering and terrorist financing." The interagency statement made clear that "the

The Federal Reserve Board ("FRB") is considering upgrading the U.S. payment system to provide payment-by-payment interbank settlement in real time ( i.e., real-time gross settlement, or "RTGS"). On October 3, 2018, the FRB requested comments from the public on (i) the adoption of an RTGS settlement service, which would enable settlement on a 24/7/365 basis, and (ii) whether the FRB or the private sector should provide a liquidity management tool in support of RTGS settlement services. Comments on the FRB's potential actions are due by December 14, 2018. In remarks before the FedPayments

In remarks before the U.S. Senate Committee on Banking, Housing and Urban Affairs, Federal Reserve Board ("FRB") Vice Chair for Supervision Randal K. Quarles described the "business mix, complexity and interconnectedness, and risk profile of banking institutions" when tailoring regulations under the Economic Growth, Regulatory Relief and Consumer Protection Act ("EGRRCPA"). He stated that the FRB will: not require bank holding companies ("BHCs") with less than $100 billion in assets to comply with requirements related to, among other things, resolution planning, internal liquidity stress

The Investment Company Institute ("ICI") urged the SEC to adopt the SEC proposal that would establish a pilot program to evaluate how exchange transaction fees and rebates affect market quality for national market system ("NMS") stocks. As previously covered, the proposed new rule - Regulation NMS Rule 610T - provides for a pilot program to monitor the effects of transaction-based fees and rebates on order routing behavior, execution quality and market quality. ICI stated in a comment letter that it "emphatically" believes the proposal will benefit investors by generating data that the SEC can

SEC Division of Enforcement (the "Division") Co-Director Steven Peikin recommended the Division consider the efficacy of both monetary and non-monetary penalties on a case-by-case basis, noting that non-monetary relief can be just as effective in achieving SEC goals. In remarks at PLI's White Collar Crimes 2018 event, Mr. Peikin said that while civil penalties "attract headlines" and serve a strong deterrent purpose, these measures are not always warranted if remedial efforts are taken. Non-monetary penalties (such as repayments or the implementation of enhanced accounting controls) also can