The OCC issued final guidelines (the “Final Guidelines”) that call for strengthened governance and risk management practices at the following categories of large financial institutions with $50 billion or more in average...more
The Office of Foreign Assets Control (“OFAC”) posted a summary of a settlement with a bank (the “Bank”) relating to a transaction that OFAC alleged was processed by the Bank in violation of OFAC’s Sudanese Sanctions...more
The OCC released an interpretive letter (“Letter #1142”) in which it concluded that a national bank’s proposal to arrange for third-party repair and maintenance service providers to service on-lease railcars and act as an...more
The FRB recently issued an interpretive letter (the “FRB Letter”) in which the FRB granted an individual director (the “Director”) an exemption from the prohibition of the Depository Institution Management Interlocks Act (the...more
On July 22, 2014, the OCC issued a bulletin (OCC Bulletin 2014-35, the “Bulletin”) in which the OCC describes the special characteristics of mutual federal savings associations (“Mutual FSAs,” and, collectively with...more
The FDIC issued guidance (the “Guidance”; FIL-40-2014) to banks and savings associations that have elected S-corporation tax treatment (collectively, “S-corporation Banks” and each an “S-corporation Bank”) concerning the...more
In remarks delivered to the FRB’s Third Annual Stress Test Modeling Symposium FRB Governor Daniel K. Tarullo focused on the “qualitative assessment of [large] firms’ capital planning processes” that the FRB conducts “in...more
The FRB, FDIC and OCC (collectively, the “Agencies”) issued a final version of an addendum (the “Addendum”) to their “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure” (the “Policy...more
The OCC issued a revised and updated booklet (the “Revised Booklet") concerning collective investment funds (“CIFs”). The Revised Booklet is part of the OCC’s “Comptroller’s Handbook.” The Revised Booklet (which updates the...more
The FRB, FDIC and OCC (the “Agencies”) published the first of a series of four requests seeking public comments to identify regulations of the respective Agencies that are seen as outdated, unnecessary or unduly burdensome. ...more
The U.S. District Court for the Eastern District of Missouri (the “District Court”) issued a memorandum and order (the “Order”) in which the District Court upheld a decision of the FDIC that contract damages sought by the...more
The New York Department of Financial Services (the “NYDFS”) plans to include cyber security as part of its bank examination process. The NYDFS issued a report (the “Report“) entitled “Report on Cyber Security in the Banking...more
The SEC’s Office of Municipal Securities has updated its frequently asked questions (the “FAQs”) that present its views regarding various aspects of the SEC’s municipal advisor registration rules (the “Final Rules”). (See...more
On May 2, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-33 (the “Notice”) providing that calendar years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration...more
The SEC issued a release proposing recordkeeping, reporting, and notification requirements for security-based swap dealers (“SBSDs”) and major security-based swap participants (“MSBSPs”). Although described as seeking to...more
The OCC proposed to increase assessments for national banks and federal savings associations with assets of more than $40 billion. The proposal would not increase assessments for national banks and federal savings...more
On April 10, 2014, Comptroller of the Currency Thomas J. Curry presented remarks concerning risk management and related corporate governance issues before the American Bankers Association Risk Management Forum. Comptroller...more
On April 15, 2013, the Basel Committee on Banking Supervision (the “Basel Committee”) issued final rules (the “Final Rules”) concerning the supervisory framework for measuring and controlling large exposures, setting tighter...more
On April 8, 2014, the FRB, FDIC and OCC (collectively, the “Agencies”) released a final rule (the “Final Rule”) concerning the leverage ratio standards for large, interconnected U.S. banking organizations. The Final Rule...more
The Basel Committee on Banking Supervision (the “Basel Committee”) of the Bank for International Settlements issued a revised set of guidelines (the “Guidelines”) concerning the external audits of banks. The Basel Committee...more
The FRB released the results of its annual large bank holding company capital assessment exercise known as the Comprehensive Capital Analysis and Review (“CCAR”). The FRB evaluated the capital adequacy and planning processes...more
The FRB released the summary results of the 2014 annual stress tests conducted by large financial institutions pursuant to the Dodd-Frank Act. 30 banking organizations participated in the 2014 stress tests. The financial...more
In a speech presented to the Association of Certified Anti-Money Laundering Specialists on March 17, 2014, Comptroller of the Currency Thomas J. Curry said that the OCC is seeing progress in terms of the priority that senior...more
The FRB released a supervisory letter (the “Letter”) regarding the FRB’s applications process intended to provide financial institutions and the general public with a better understanding of the FRB’s approach to processing...more
On January 14, 2014, the House of Representatives passed H.R. 801, the Holding Company Registration Threshold Equalization Act of 2013 (the “Act”), which would increase the number of shareholders that trigger registration and...more