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President Trump Sends Three Financial Regulatory Nominations to the Senate

On February 12th, the White House announced numerous nominations to be sent to the Senate. The large list of nominations included three nominations for financial regulators. President Trump is nominating, Jonathan Gould to be...more

FRB, FDIC, OCC and NCUA Testify at Congressional Oversight Hearings

This week, the Senate Banking Committee and the House Financial Services Committee held oversight hearings with leaders of the Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”), the National Credit...more

Federal Banking Agencies Finalize Community Reinvestment Act Rules

On Tuesday, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a final rule to amend and update...more

Vice Chair Barr Speaks on Capital Endgame Proposal

On Monday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the American Bankers Association Annual Convention entitled Capital Supports Lending regarding the Basel III...more

Industry Trades Really Don’t Like the Basel III Endgame Proposal

As we covered previously, on July 27, 2023, the U.S. prudential bank regulators (the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”)...more

The Three Federal Banking Agencies Propose Long-Term Debt Requirement for All Large Banking Organizations

The Federal Deposit Insurance Corporation (“FDIC”), Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a proposed rule (the “LTD NPR”) to require large banks...more

Capital Idea? Risk-Based Capital, Capital Relief Trades and the Proposed Basel III Endgame Capital Rules

On July 27, 2023, the U.S. federal prudential bank regulators (the Federal Deposit Insurance Corporation, the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency) proposed new capital requirements...more

Banking Agencies Finalize Interagency Policy Statement on CRE Loan Workouts

On June 30, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Office of the Comptroller of the Currency (“OCC”) and the National Credit Union Administration (“NCUA”) finalized their Policy...more

Agencies Issue Proposed Interagency Guidance on Real Estate Appraisal Reconsiderations of Value

Last week, the Office of the Comptroller of the Currency (“OCC”), Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”), and the Consumer Financial...more

OCC Issues Latest Semiannual Risk Perspective

The Office of the Comptroller of the Currency (“OCC”) issued its Semiannual Risk Perspective for Spring 2023 (“SARP”) recently. The OCC highlighted liquidity, operational, credit, and compliance risks, among the key risk...more

Banking Agencies Finalize Interagency Guidance on Third-Party Risk Management

On June 6, the three Federal bank regulatory agencies (the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)), issued final interagency...more

OCC Issues Updated Enforcement Action Policies and Procedures Manual

The Office of the Comptroller of the Currency (“OCC”) issued an updated Policies and Procedures Manual (PPM 5310-3) on Bank Enforcement Actions and Related Matters last week. The PPM is updated from the 2018 issuance. The...more

OCC and FDIC Provide Supervisory Guidance on Certain Overdraft Practices

The Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the “Agencies”) provided supervisory guidance this week on certain overdraft practices. Of particular...more

Acting Comptroller Hsu Compares FTX to BCCI Rather than Other Failures

This week, Acting Comptroller of the Currency Michael Hsu delivered remarks, titled “Trust and Global Banking: Lessons for Crypto,” at the Institute of International Bankers’ (“IIB”) Annual Washington Conference in which he...more

Banking Agencies Issue Joint Statement on Crypto-related Liquidity Risks

Earlier yesterday, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”) issued a “Joint Statement on Liquidity Risks to Banking Organizations...more

FRB and OCC Release 2023 Stress Test Scenarios

The Federal Reserve Board (“FRB”) and Office of the Comptroller of the Currency (“OCC”) last week released their 2023 Dodd-Frank Act Stress Test (“DFAST”) scenarios. As noted in the FRB’s release, the “stress tests help...more

Acting Comptroller Hsu Speaks on Too-Big-to-Manage Rather Than Too-Big-to-Fail

Acting Comptroller of the Currency Michael Hsu delivered remarks, titled “Detecting, Preventing, and Addressing Too Big To Manage,” at the Brookings Institution yesterday in which he addressed and offered a possible solution...more

Banking Agencies Extend Reg. O Relief

On December 22, just before many of us may have started turning to our holiday breaks, the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)...more

FRB and FDIC Issue Joint ANPR on Possible Resolution Requirements for Large Banking Organizations While FRB and OCC Approve U.S....

The Federal Reserve Board (“FRB”) and Federal Deposit Insurance Corporation (“FDIC”) Board issued an Advanced Notice of Proposed Rulemaking (“ANPR”) titled “Resolution-Related Resource Requirements for Large Banking...more

OCC Releases Bank Supervision Operating Plan

Last week, just after we went to press, the Office of the Comptroller of the Currency (“OCC”) released its Bank Supervision Operating Plan for Fiscal Year 2023.  The Operating Plan sets out the OCC’s supervision...more

In Depth: Summary of Notable Comments to Federal Banking Agencies’ Interagency Proposal to Update Community Reinvestment Act Rules

As we reported in May, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a notice of proposed...more

FRB Vice Chair Brainard Touts CRA Proposal and Positive Impacts on Native American Communities

On July 19, Federal Reserve Board (“FRB”) Vice Chair Lael Brainard gave remarks to the National Native Coalition Virtual Series sponsored by the National Congress of American Indians. Her remarks focused on the joint proposal...more

Five Federal Agencies Issue Joint Statement on Approach to Customer Due Diligence

On July 6, five federal agencies − the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Financial Crimes Enforcement Network (“FinCEN”), National Credit Union...more

OCC Issues Its Semiannual Risk Perspective

The Office of the Comptroller of the Currency (“OCC”) issued its Semiannual Risk Perspective for Spring 2022 on June 23. This was the same day the Federal Reserve released the results of its stress test for large bank holding...more

In Depth: A Look at Federal Banking Agencies’ Proposal to Update Community Reinvestment Act Rules

As we mentioned briefly in our newsletter last week, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”)  and the Office of the Comptroller of the Currency (“OCC”) (together, “The Agencies”)...more

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