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 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 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
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 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
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
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
On October 5, 2017, the Consumer Financial Protection Bureau (“CFPB”) released its nearly 1,700-page final rule for short-term loans (“Payday Lending Rule”). Notably, almost simultaneously with the CFPB’s announced Payday...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
On August 22, 2017, the Office of the Comptroller of the Currency (the “OCC”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Board of Governors of the Federal Reserve System (the “FRB”) (the OCC, FDIC and FRB...more
8/28/2017
/ Basel III ,
Capital Requirements ,
Community Banks ,
Dodd-Frank ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Mortgage Servicers ,
OCC ,
Proposed Regulation ,
Regulatory Freeze ,
Tax Deferral
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