PPP 2.0 – A Renewed Opportunity (and New Set of Headaches) for Lenders
As the old saying goes, the best deals are made when neither side gets exactly what it wants. By that standard, the most recent federal pandemic relief bill that finally passed into law in late December certainly qualifies as a great deal. Democrats who for months had been seeking a bill in excess of $3 […]
A Farewell to Paul Sarbanes
Almost four years ago, I wrote a blog, “A Farewell to Michael Oxley,” paying tribute to the former Republican member of the U.S. House of Representatives who died on January 1, 2016. Today, it is fitting that we issue another farewell. On December 7, the family of Paul Sarbanes announced the death of the former […]
SolarWinds Vulnerability Update – Indicators of Compromise and Recommended Actions
The news of the cyber attacks being experienced by government agencies and an expanding list of organizations continues to grow and change on almost an hourly basis. This is proving to be potentially one of the most significant cyber breaches in recent times. Following up on our December 14, 2020, Flash Report on the CISA […]
FinCEN and OFAC Put Financial Institutions on Notice About Processing Ransomware Payments
The U.S. government has officially put financial institutions on notice: It is watching and may impose anti-money laundering (AML) sanctions on payment facilitators if they violate federal laws on engaging in transactions, such as ransomware payments, with sanctioned individuals or entities – intentionally or otherwise. For as long as ransomware incidents have occurred, the controversial […]
CFPB Provides Further Guidance on MSAs Under RESPA Section 8
The Consumer Financial Protection Bureau (CFPB) issued a compliance aid in October 2020 to provide regulated entities greater clarity around the Real Estate Settlement Procedures Act (RESPA) and certain provisions of Regulation X. The compliance aid, presented in the form of Frequently Asked Questions (FAQs), focuses on RESPA Section 8, which prohibits certain actions related […]
Recharging Your Agile Transformation
The seismic shift in project management functions from administrative to a consultative business partner is helping organizations transform across the enterprise and all areas of the project life cycle. In many companies, these transformational efforts are progressing well, coordinated by new lean-agile program management office (PMO) leaders. But for others, transformation is still out of […]