The Office of the Comptroller of the Currency (OCC) released guidance regarding its planned changes to the Bank Merger Act (BMA). The New Rule:
Explicitly adds financial stability as a key factor for assessing mergers,...more
On March 29, 2021, the primary federal bank regulators (the Federal Reserve, CFPB, the FDIC, the NCUA, and the OCC) issued a request for information to gain input on the growing use of Artificial Intelligence (“AI”) by...more
4/2/2021
/ Artificial Intelligence ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
NCUA ,
OCC ,
Popular ,
Risk Management
I had the pleasure of presenting at Bank Director Magazine's Inspired By Acquire or Be Acquired: What Officers and Directors Need to Know Now virtual conference, along with Rick Levin, earlier this month.
Our...more
3/4/2021
/ Banking Sector ,
Banks ,
Bitcoin ,
Blockchain ,
Cryptocurrency ,
Digital Assets ,
Digital Currency ,
Financial Institutions ,
FinCEN ,
OCC ,
Virtual Currency
So let’s dance this last dance. On Jan. 4, 2021, the Office of the Comptroller of the Currency (“OCC”) published a Chief Counsel’s Interpretative Letter (the “Letter”) confirming the authority of national banks’ and federal...more
The Office of the Comptroller of the Currency (“OCC”) issued its long-anticipated final rule on Oct. 27, to establish a “simple, bright-line test” to determine when a national bank or federal savings association has made a...more
As anticipated, on July 20, 2020, the Office of the Comptroller of the Currency (“OCC”) proposed rulemaking to determine that when a national bank or federal savings association makes a loan it is the “true lender,” when...more
The Office of the Comptroller of the Currency (“OCC”) adopted a final rule on June 2, 2020 that clarifies that when a bank transfers a loan, the interest permissible before the transfer continues to be permissible after the...more
The Office of the Comptroller of the Currency (OCC) released “OCC Bulletin 2020-44” which encourages institutions to “prudently document their implementation and lending decisions” under the Small Business Administration's...more
Last week the Department of Justice (DOJ) announced criminal charges against U.S. Bancorp “consisting of two felony violations of the Bank Secrecy Act (‘BSA’) by its subsidiary, U.S. Bank National Association (the ‘Bank’),...more