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The Federal Deposit Insurance Corporation ("FDIC") issued a Financial Institution Letter encouraging supervised institutions to take a risk-based approach when assessing individual customer relationships. This approach would be preferable to the alternative where an institution simply declines to provide banking services to entire categories of customers. The FDIC noted that if an institution follows existing guidance, and establishes and maintains an appropriate risk-based program, then the institution should be well positioned to manage customer accounts appropriately while detecting and

The SEC announced that it will hold a roundtable on February 19, 2015 to explore ways to improve the proxy voting process. The roundtable will be divided into two panel discussions: the first panel will focus on (i) the state of contested director elections, and whether changes should be made to the federal proxy rules to facilitate the use of universal proxy ballots by management and proxy contestants, and (ii) state law, logistical and disclosure issues presented by a possible universal proxy ballot process; the second panel will focus on (i) strategies for increasing retail shareholder

At a full committee hearing of the Federal Housing Finance Agency ("FHFA"), House Financial Services Committee Chair Jeb Hensarling (R-TX) delivered an opening statement in which he asserted that, through the FHFA, Washington is repeating the same mistakes that caused the financial crisis. At the hearing, which was titled "Sustainable Housing Finance: An Update from the Director of the Federal Housing Finance Agency," Chair Hensarling asserted that the cause of the financial crisis was "dumb regulation" rather than deregulation, and stemmed from "Washington greed"; i.e., from lust for the

In separate actions, the SEC and the Financial Crimes Enforcement Network ("FinCEN") charged Oppenheimer & Co. ("Oppenheimer") with violating federal securities laws, as well as the Bank Secrecy Act ("BSA"), while selling penny stocks improperly in unregistered offerings on behalf of customers. According to the SEC Order, Oppenheimer was involved in: aiding and abetting illegal activity by a customer; failing to file Suspicious Activity Reports to report the potential misconduct by the customer, and improperly recording the transactions in Oppenheimer's books and records; ignoring red flags