The Office of the Comptroller of the Currency (“OCC”) recently sought comment on a proposed rule designed to increase the transparency of the standards applicable to the OCC’s review of business combinations (i.e., bank...more
The Federal Deposit Insurance Corporation (“FDIC”) recently published a Federal Register notice seeking public comment on proposed revisions to the FDIC’s Statement of Policy on Bank Merger Transactions (the “SOP”). Relevant...more
The Office of the Comptroller of the Currency (“OCC”) recently sought comment on a proposed rule designed to increase the transparency of the standards applicable to the OCC’s review of business combinations (i.e., bank...more
On October 24, 2023, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together, the “Agencies”) issued a final rule designed to...more
On July 28, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the National Credit Union Administration (the “NCUA”) and the Office of the...more
On July 27, 2023, in an effort to bolster the resilience of the U.S. banking system in the aftermath of recent bank failures and to promote consistency with international banking capital standards, the Federal Deposit...more
On March 24, 2020, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) issued a statement on its supervisory activities (“Statement”) during the unprecedented COVID-19 pandemic. As part of that...more
Over the past two weeks, we have received numerous inquiries from financial institutions on what actions should be taken or considered to address the COVID-19/Coronavirus pandemic. While every bank is different and the...more
3/22/2020
/ Banks ,
Business Continuity Plans ,
Coronavirus/COVID-19 ,
Emergency Management Plans ,
FDIC ,
FFIEC ,
Financial Institutions ,
Infectious Diseases ,
Popular ,
Remote Working ,
Risk Management ,
Workplace Safety
On September 17, 2019, the Federal Deposit Insurance Corporation (the “FDIC”) passed a final rule providing qualifying community banking organizations the ability to opt-in to a new community bank leverage ratio (“CBLR”)...more
9/27/2019
/ Banking Sector ,
Banks ,
Community Banks ,
Consumer Protection Act ,
Dodd-Frank ,
EGRRCPA ,
FDIC ,
Final Rules ,
Financial Institutions ,
Leverage Capital Ratio ,
Opt-In
On September 17, 2019, the Securities and Exchange Commission (the “SEC”) proposed rules that would update the statistical disclosures currently required by Industry Guide 3, Statistical Disclosure by Bank Holding Companies...more
9/24/2019
/ Bank Holding Company ,
Banking Sector ,
Banks ,
Comment Period ,
Disclosure Requirements ,
Financial Reporting ,
Investors ,
Loans ,
Proposed Rules ,
Public Comment ,
Regulation S-K ,
Savings and Loan Companies ,
Securities and Exchange Commission (SEC)
On July 9, 2019, the Board of Governors of the Federal Reserve System (the “FRB”), U.S. Commodity Futures Trading Commission, Federal Deposit Insurance Corporation (the “FDIC”), Office of the Comptroller of the Currency (the...more
8/5/2019
/ Banking Sector ,
Banks ,
CFTC ,
Exemptions ,
FDIC ,
Hedge Funds ,
Investment Opportunities ,
Investment Portfolios ,
Investors ,
OCC ,
Private Equity Funds ,
Proprietary Trading ,
Securities and Exchange Commission (SEC) ,
Volcker Rule
On October 31, 2018, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Office of the Comptroller of the Currency (the “OCC”) and the Federal Deposit Insurance Corporation (the “FDIC”) issued a...more
11/2/2018
/ Banking Sector ,
Banks ,
Capital Requirements ,
FDIC ,
Federal Reserve ,
Liquidity Risk Management Rule ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Proposed Rules ,
Regulatory Oversight ,
U.S. Treasury
In a recent interview, Comptroller of the Currency Joseph Otting, announced the OCC’s plan to “clarify” its support of bank-offered deposit advance products. “Deposit advance products” are typically defined as small-dollar,...more
4/2/2018
/ Banking Sector ,
Banks ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Deposit Advances ,
Direct Deposit ,
Loans ,
OCC ,
Payday Lending Rule ,
Payday Loans ,
Rescission
In November 2016, with the election results confirmed, the banking industry was awash in hopes for a more lenient regulatory posture. To date, the industry has seen no reform. However, on March 14, 2018, the Senate passed and...more
3/19/2018
/ Bank Holding Company ,
Banking Sector ,
Banks ,
Community Banks ,
Community Reinvestment Act ,
Consumer Protection Act ,
Disclosure Requirements ,
Federal Deposit Insurance Act ,
Federal Savings Associations ,
Financial Institutions ,
HMDA ,
HVCRE ,
HVCRE Loans ,
Mortgages ,
Policy Statement ,
Prudential Standards ,
Regulatory Agenda ,
Rulemaking Process ,
Volcker Rule
On October 27, 2017, the Office of the Comptroller of the Currency (OCC) issued a full-service national bank charter since the financial crisis to Winter Park National Bank. Winter Park National Bank is the first de novo...more
On September 14, 2017, the Consumer Financial Protection Bureau (the “CFPB”) issued its first no-action letter (the “No-Action Letter”) concerning the operations of Upstart Network, Inc. (“Upstart”), a FinTech lender that...more
On July 10, 2017, the Consumer Financial Protection Bureau (the “CFPB”) finalized its proposed arbitration rule that will prohibit providers of certain consumer financial products and services from requiring a consumer to...more
7/13/2017
/ Arbitration ,
Banks ,
Class Action Arbitration Waivers ,
Congressional Review Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
FinTech ,
Mandatory Arbitration Clauses ,
Mortgage Lenders ,
OCC ,
Pre-Dispute Arbitration ,
Trump Administration