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 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 a notice of proposed rulemaking (the “Proposed Rule”) that would revise the FDIC’s risk-based deposit insurance assessment system to reflect the final Basel III capital rule (the “Final Capital Rule”) adopted...more
The Federal Financial Institutions Examination Council (the “FFIEC”) announced that it had established a web page on cybersecurity (the “Web Page”), which is designed to serve as a central repository for current and future...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a series of four requests seeking public comments to identify regulations of the respective Agencies that are seen as outdated, unnecessary or unduly burdensome.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 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 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
On April 2, 2014 the members of the Federal Financial Institutions Examination Council (“FFIEC”) issued two joint statements: the first joint statement regards distributed denial-of-service (“DDoS”) attacks, and the second...more
The OCC, FRB and FDIC (collectively, the “Agencies”) issued joint final guidance (the “Final Guidance”) concerning the Agencies’ key supervisory expectations regarding how medium-sized banking organizations--those with more...more
The Office of the Comptroller of the Currency (the “OCC”) issued an update to its Mortgage Banking booklet of the Comptroller’s Handbook, which was last updated in March 1996. The Mortgage Banking booklet generally provides...more
The OCC issued proposed guidelines (the “Proposed Guidelines”) that would establish minimum standards for the design and implementation of a risk governance framework (the “Risk Framework”) by national banks, federal savings...more
The Federal Reserve Board, the OCC, the FDIC, the SEC and the CFTC (collectively, the “Agencies”) adopted an interim final rule (the “Interim Rule”) that provides relief from certain requirements of the Volcker rule for...more
1/15/2014
/ Bank Holding Company Act ,
Banks ,
CFTC ,
Collateralized Debt Obligations ,
Compliance ,
Dodd-Frank ,
FDIC ,
OCC ,
Securities and Exchange Commission (SEC) ,
Trust Preferred Securities ,
Volcker Rule
JPMorgan Chase & Co. and its affiliates (collectively, “JPMorgan”) agreed to pay an aggregate of $2.05 billion to resolve civil and criminal claims generally related to JPMorgan’s Bank Secrecy Act (“BSA”) compliance program...more
1/15/2014
/ Bank Secrecy Act ,
Bernie Madoff ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
FinCEN ,
Fraud ,
JPMorgan Chase ,
OCC ,
Ponzi Scheme ,
Settlement ,
Suspicious Activity Reports (SARs)
The FRB, the FDIC, and the OCC (the “Agencies”) issued a joint FAQ clarifying certain aspects of the treatment of interests in collateralized debt obligations backed by trust preferred securities (“TruPS CDOs”) under the...more
12/27/2013
/ Banking Sector ,
Collateralized Debt Obligations ,
Dodd-Frank ,
FDIC ,
Financial Regulatory Reform ,
FRB ,
Investment Funds ,
OCC ,
Securities ,
Trust Preferred Securities ,
Volcker Rule
The OCC issued an interpretive letter (“Letter #1139”), in which the OCC concluded that a national bank (the “Bank”) could provide financing for a renewable energy solar project (the “Facility”) in which the financing was...more
The Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency and the Securities and Exchange Commission jointly adopted and the Commodity Futures Trading Commission...more
12/13/2013
/ Banks ,
CFTC ,
Dodd-Frank ,
FDIC ,
Federal Reserve ,
Hedge Funds ,
Market Making ,
OCC ,
Private Equity ,
Proprietary Trading ,
Securities and Exchange Commission (SEC) ,
Volcker Rule
The FDIC, FRB and OCC (the “Agencies”) each made available a regulatory capital estimation tool (the “Estimation Tool”) that is designed to help community banks evaluate the potential impact on their capital ratios of the...more
The OCC, FDIC, and FRB jointly issued final updates to the Interagency Questions and Answers Regarding Community Reinvestment. The final changes (the “Final Q&As”) focus primarily on issues concerning community development...more
The OCC issued guidance (the “Guidance,” OCC Bulletin 2013-33) that establishes standards that the OCC will use when it requires national banks, federal savings associations or federal branches or agencies (collectively,...more
The OCC issued updated and comprehensive guidance (OCC Bulletin 2013-29, the “Guidance”) to national banks and federal savings associations (collectively, “Banks”) concerning assessment and management of risks associated with...more