On October 30, two leading fintech industry trade associations submitted comments (see comment letters here and here) in response to a joint Request for Information (RFI) issued by the Office of the Comptroller of the...more
11/4/2024
/ Banking Sector ,
Banks ,
FDIC ,
Financial Institutions ,
Financial Regulatory Agencies ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
OCC ,
Request For Information ,
Rulemaking Process
On October 3, the OCC issued Bulletin 2024-29, providing guidance for managing credit risk in connection with refinancing commercial loans.
The bulletin is directed at all banks with commercial loan portfolios, and...more
On March 21, the FDIC, Fed, and OCC jointly issued an interim final rule to extend the applicability date of certain provisions of the Community Reinvestment Act (CRA) final rule and requested comments on the extension. The...more
4/8/2024
/ Banks ,
Community Development ,
Community Reinvestment Act ,
FDIC ,
Federal Reserve ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lending ,
OCC ,
Rulemaking Process
On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more
2/19/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
CFTC ,
Compliance ,
FDIC ,
Final Rules ,
Financial Services Industry ,
FinCEN ,
FinTech ,
NCUA ,
Non-Depository Institutions ,
OCC ,
OTS ,
Regulatory Agenda ,
Regulatory Requirements ,
Risk Assessment ,
Risk Management ,
Securities and Exchange Commission (SEC)
On February 5, several trade groups, including the American Bankers Association, the Independent Community Bankers of America, and the U.S. Chamber of Commerce, filed suit against the Federal Reserve Board, the FDIC, and the...more
On January 2, 2024, New York Governor Kathy Hochul announced “a sweeping consumer protection and affordability agenda,” what she termed as the “most significant expansion of consumer laws since 1980.” As part of that agenda,...more
On November 1, the OCC issued Bulletin 2023-34 addressing the topic of “venture lending,” referred to as “commercial loans to early-, expansion-, and late-stage companies.” According to the Bulletin, venture lending is often...more
On June 16, Michael Hsu, the Acting Comptroller of the Currency gave remarks at the American Bankers Association’s Risk and Compliance Conference about the risks of tokenization and AI on the banking industry. While...more
On June 6, the FDIC, FRB & OCC issued final interagency guidance intended to assist their respective supervised banking organizations in identifying and managing risks associated with third-party relationships and in...more
On January 27, the Federal Reserve Board (FRB) announced that it unanimously voted to deny a crypto firm’s application to become a member of the Federal Reserve System. This denial ends the crypto firm’s 27-month effort to...more
On November 29, the OCC released a revised Policies and Procedures Manual relating to the assessment of civil money penalties (“CMP Matrix”), which will be effective as of January 1, 2023. The CMP Matrix is a reference guide...more
On September 7, Acting Comptroller of the Currency, Michael Hsu, discussed the long-term threats to trust in banking in remarks at the TCH + BPI Annual Conference. Hsu provided updates on key priorities at the OCC, including...more
9/16/2022
/ Banking Sector ,
Banks ,
BSA/AML ,
Comptroller ,
Cryptocurrency ,
FDIC ,
Federal Reserve ,
Financial Services Industry ,
FinTech ,
OCC ,
Risk Management
On May 24, the acting Comptroller of the Currency, Michael Hsu remarked at the DC Blockchain Summit 2022 about his observations on the “deep” vulnerabilities of cryptocurrency in light of the recent market volatility and...more
The May 1 change to banks’ cyber-notification process is fast approaching. As we wrote previously the OCC, FDIC, and Federal Reserve Board implemented a final rule under which banks and their service providers must notify...more
On April 8, the acting comptroller of the currency, Michael J. Hsu, discussed many aspects of stablecoins (we previously discussed the President’s Working Group report on stablecoins and Hsu’s comments...). In his speech at...more
A few months ago, we published a post about the OCC, FDIC, and Federal Reserve Board’s final rule to improve information sharing about cyber incidents that may affect the U.S. banking system. Under the final rule, banks and...more
On March 3, Virginia passed a new bill (HB 263) permitting banks in the Commonwealth to provide its customers with crypto custody services “so long as the bank has adequate protocols in place to effectively manage risks and...more
On February 8, the House Financial Services Committee held a hearing titled, “Digital Assets and the Future of Finance: The President’s Working Group on Financial Markets” to consider legislative recommendations from the...more
On February 8, the U.S. District Court for the Northern District of California ruled against three states – California, Illinois, and New York – challenging the OCC’s rule on the “valid when made” doctrine. In 2020, the OCC...more
On November 3, Acting Comptroller of the Currency, Michael J. Hsu, remarked at the BritishAmerican Business Transatlantic Finance Forum 2021-2022 Executive Roundtable about the regulation of stablecoins and other...more
Last month, the FDIC, Federal Reserve Board, and the OCC announced a final rule to improve information sharing about cyber incidents that may affect the U.S. banking system. Among other things, the final rule requires...more
On November 18, the Chief Counsel of the Office of the Comptroller of the Currency (OCC) issued a fourth interpretive letter (Letter 1179) regarding whether it is permissible for national banks and federal savings...more
On November 23, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (“banking agencies”) released a joint statement recognizing that the...more
Building on his remarks to the Blockchain Association and the American Fintech Council earlier this month, the Acting Comptroller of the Currency, Michael J. Hsu, issued a statement on November 16 before the Federal Reserve...more
On November 3, Acting Comptroller of the Currency, Michael J. Hsu, remarked at the American Fintech Council’s Fintech Policy Summit 2021 about the growth in the digitalization of banking including the trend and attendant...more