Alston & Bird Consumer Finance Blog


Avoiding Pitfalls During Post-Pandemic Government Investigations

As the country begins to emerge from the COVID-19 pandemic and the U.S. economy gets back on track, banks nationwide should expect their activities to come under government scrutiny. The impacts of the coronavirus have touched every corner of the banking industry as institutions have striven to meet the evolving needs of their customers, continue operations in a remote working environment, and stand up new programs in response to government relief efforts, such as the Coronavirus Aid, Relief, and Economic Security (CARES) Act. With 2020 in the rearview mirror, banks’ efforts to balance these challenges during a year of unprecedented changes will be put under the microscope as their compliance with an ever-expanding list of laws and regulations is assessed by regulators. The conduct of banks’ management, service providers, and even customers will likewise be reviewed.

CSI: Confidential Supervisory Information is not a show many banks would enjoy watching, but in a recent advisory it’s one of three areas our Financial Services & Products Group notes banks should keep in mind if they become the subject of subpoenas, document requests, examinations, or investigations by government agencies.