Washington Report 360 | November 4, 2022

Third party risk management. Cybersecurity and Ransomware. Accountability/Trust. Liquidity Risks.

Key Highlights

TPRM. SEC proposed rules that would establish oversight requirements for investment advisers that retain service providers to perform “covered functions.” (See KPMG Regulatory Alert, here)
Cybersecurity and Ransomware. Treasury said information sharing with financial institutions helped thwart cyberattack; FinCEN financial trend analysis report finds nearly $1.2 billion ransomware-related filings in 2021; White House Fact Sheet on ransomware summit.
Accountability/Trust. SEC Chair speech outlining “effective administration” of the federal securities laws focuses on importance of “positions of trust”
Liquidity Risks. SEC proposed enhancements to the liquidity framework of open-end funds to “better prepare for stressed conditions.”

Financial services regulatory news
SEC	New rule proposal on third party oversight requirements for investment advisers that retain services providers to perform covered functions Amendments to Form N-PX to enhance proxy voting reporting by mutual funds, exchange-traded funds, and certain other registered funds Proposed enhancements to open-end fund liquidity framework Final rule imposing Compensation Recovery Listing Standards and Disclosure Rules on securities exchanges (See KPMG DPP Financial Reporting View, here) Speech: The Law and its Effective Administration
CFTC	No-action letter relating to extension of swap reporting requirements
FINRA	Regulatory notice guidance on succession planning Podcast discussing review and approval of digital asset firm membership applications
FRB	Pricing announcement, effective January 3, 2023, for Federal Reserve Bank payment services, including FedNow Services
CFPB	Remarks on BNPL, P2P payments, and open banking Blogs: Seeking public input on big tech payment platforms Update on student loan borrowers during payment suspension
Treasury	FinCen financial trend analysis on ransomware BSA reporting Speech on “whole-of-government” approach to ransomware threats FATF updates two lists of jurisdictions with strategic AML/CFT/CPF deficiencies
FTC	Enforcement action against a tech provider for alleged data security practice weaknesses PrivacyCon 2022 Event featuring seven panels including consumer surveillance, automated decision-making systems, and adtech Remarks at PrivacyCon 2022 relating to technological emerging risks and data privacy
BIS	Bulletin on global exchange rate adjustments BIS Innovation Hub launch of new project around CBDCs and DeFi protocols

Financial services policy news
White House	Fact sheets on: Second international counter ransomware initiative summit; related joint statement Net-Zero Game Changers initiative (research in clean technologies funded by the Inflation Reduction Act)