June 8, 2023 By: Stephanie Shea and Michael Flynn On June 6, 2023, the FDIC, FRB and OCC collectively issued a document entitled, “Interagency Guidance on Third-Party Relationships: Risk Management” (“2023 Guidance”). Prior...more
In its recent Semiannual Risk Perspective, the Office of the Comptroller of the Currency (OCC) has highlighted the difficulties banks face finding adequate numbers and quality of hires for compliance oversight. While there...more
Under the long-recognized valid when made doctrine, if a loan was not subject to a state usury law when it was made, it does not subsequently become even if it is subsequently sold or assigned to another party. The doctrine...more
On October 29, the OCC, the Federal Reserve, the FDIC, the NCUA and the CFPB (collectively, the “agencies”) issued a Notice of Proposed Rulemaking (“NPR”) to clarify and make into a rule the prior Interagency Statement...more
On October 27, the Office of the Comptroller of the Currency issued a final rule that establishes a new standard for when a national bank or Federal savings association (“bank”) is the “true lender” in a lending arrangement...more
On July 20, the Office of the Comptroller of the Currency proposed a rule which, if finalized as a rule, would establish a new standard for when a national bank or Federal savings association (“bank”) is the “true lender” in...more
On May 20, 2020, the Office of the Comptroller of the Currency (OCC) issued as new final rule updating various aspects of the requirements of the Community Reinvestment Act (CRA). The rule is effective on October 1, 2020....more
On December 12, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) issued a proposed rule that would result in major changes to the rules applying the Community...more
12/16/2019
/ Banking Sector ,
Comment Period ,
Community Reinvestment Act ,
Depository Institutions ,
FDIC ,
Federal Reserve ,
Low Income Housing ,
OCC ,
Proposed Rules ,
Regulatory Standards ,
Small Banks
On November 19, the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking (FDIC Notice) setting forth a proposed rule that, if ultimately adopted, would confirm that the “valid-when-made” doctrine...more
The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking (Notice) that would affirm that when a national bank or savings association sells, assigns, or...more
11/19/2019
/ Assignments ,
Comment Period ,
Consumer Lenders ,
FDIC ,
Interest Rates ,
Loans ,
NPRM ,
OCC ,
Proposed Rules ,
Sale of Assets ,
Valid When Made Doctrine