On June 28, 2024, in an effort to bolster financial institutions’ anti-money laundering and countering the financing of terrorism (“AML/CFT”) programs, the U.S. Department of the Treasury’s Financial Crimes Enforcement...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
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 April 9, 2020, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), and the Office of the Comptroller of the Currency (collectively, the “federal banking...more
On March 27, 2020, the President signed into law the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”). While the CARES Act contains a variety of provisions, including, among other things, unemployment...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
Over the past two weeks, the international markets have been roiling under news that the COVID-19 virus, commonly referred to as the coronavirus, may be spreading. The Board of Governors of the Federal Reserve System (the...more
3/6/2020
/ Business Continuity Plans ,
Capital Markets ,
Coronavirus/COVID-19 ,
Cybersecurity ,
Emergency Management Plans ,
Federal Reserve ,
FFIEC ,
Financial Institutions ,
Financial Markets ,
Interest Rates ,
U.S. Treasury
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 November 1, 2018, the Federal Deposit Insurance Corporation (the “FDIC”) issued modifications to its Statement of Policy (“SOP”) for applications made under Section 19 of the Federal Deposit Insurance Act (“FDIA”). The...more
On October 16, 2018, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation and the Board of Governors of the Federal Reserve System (the “Agencies”) issued the Frequently Asked Questions on...more
On July 11, 2018, the Office of the Comptroller of the Currency (“OCC”), the Federal Deposit Insurance Corporation (“FDIC”) and the Board of Governors of the Federal Reserve System (“FRB”) (the OCC, FRB and FDIC are...more
On May 11, 2018, compliance with the beneficial ownership rule became mandatory. In accordance with the rule, a covered financial institution must verify, at the time a new account is opened, the beneficial owners opening the...more
On April 10, 2018, the Federal Financial Institutions Examination Council (the “FFIEC”), an interagency body composed of the Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau, Federal...more
On April 3, 2018, the Department of Treasury released recommendations to “modernize” the Community Reinvestment Act of 1977 (“CRA”). Treasury’s recommendations include:...more
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 January 23, 2018, Mick Mulvaney, Acting Director of the Consumer Financial Protection Bureau (the “CFPB”), published an opinion editorial in The Wall Street Journal (the “Op-Ed”) describing his vision of the CFPB’s role in...more
2/21/2018
/ Adjudicatory Process ,
Call for Evidence ,
Civil Investigation Demand ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Act ,
Cost-Benefit Analysis ,
Dodd-Frank ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
HMDA ,
Payday Lending Rule ,
Request For Information ,
Rulemaking Process ,
UDAAP ,
Wall Street Journal
On January 17, 2018, the Consumer Financial Protection Bureau (the “CFPB”) announced that it will issue a call for “evidence” to ensure the CFPB is “fulfilling its proper and appropriate functions to best protect consumers.”...more
On December 21, 2017, under the direction of Acting Director Mick Mulvaney, the Consumer Financial Protection Bureau (the “CFPB”) announced that it intends to reopen the rulemaking process to reconsider various aspects of the...more
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 October 12, 2017, the OCC issued OCC Bulletin 2017-40 announcing the release of its Policies and Procedures Manual 5000-43 (PPM 5000-43), which outlines the OCC’s policy and framework for how the agency determines...more
Here are our observations on the 2018 OCC Bank Supervision Operating Plan:
– Cybersecurity is a top priority.
– Credit underwriting, as always.
– BSA is frequently mentioned...more
On March 15, 2017, the Office of the Comptroller of the Currency (the “OCC”) published for comment a draft supplement to the OCC’s existing Comptroller’s Licensing Manual providing detail on how the OCC will evaluate national...more
9/28/2017
/ Applications ,
Banking Sector ,
Business Plans ,
Capital Requirements ,
Corporate Strategy ,
Filing Requirements ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Internal Controls ,
OCC ,
Recordkeeping Requirements ,
Risk Assessment ,
Special Purpose National Bank Charter