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Banking Sector Banking Examinations

Goodwin

Dos and Don'ts of Interacting with Bank Regulators

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Supervision is a daily fact of life for bank boards and management. Below, we offer strategies for how both board members and members of management can ensure that the supervisory process goes as smoothly as possible....more

Latham & Watkins LLP

How Proposed Bipartisan Bill Would Reform Bank Exams

Latham & Watkins LLP on

A recent bipartisan bill, if enacted, would particularly benefit small lenders and bank/fintech partnerships by promoting transparency, appellate rights and examiner accountability. On Dec. 14, 2023, a bipartisan group of...more

Womble Bond Dickinson

OCC Issues New Version of the “Lease Financing” Booklet of the Comptroller Handbook

Womble Bond Dickinson on

On September 27, 2023, the Office of the Comptroller of the Currency (OCC) issued Version 2.0 of the Lease Financing booklet of the OCC’s Comptroller Handbook, which replaced Version 1.0 published in August 2014 and updated...more

Latham & Watkins LLP

Proposed Bill Would Reform Bank Exam Processes

Latham & Watkins LLP on

A recent bipartisan bill, if enacted, would particularly benefit small lenders and bank-fintech partnerships by promoting transparency, appellate rights, and examiner accountability. On December 14, 2023, a bipartisan...more

Sheppard Mullin Richter & Hampton LLP

OIG Issues Audit Memorandum to FDIC’s Regional Service Provider Examination Program, Impacts Fintechs

On December 21, the Office of Inspector General (OIG) of the FDIC issued its audit memorandum on the FDIC’s Regional Service Provider (RSP) Examination Program. The OIG’s objective was to assess the effectiveness of the...more

Sheppard Mullin Richter & Hampton LLP

Industry Groups to CFPB: Take Back UDAAP Anti-Discrimination Policy

On June 28, the American Bankers Association, Consumer Bankers Association, Independent Community Bankers of America, and the U.S. Chamber of Commerce affirmed in a letter to CFPB Director Rohit Chopra that the CFPB should...more

Goodwin

FDIC Seeks Comment on Supervisory Approach to Examinations During Pandemic

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC) is seeking information and comment regarding the FDIC’s supervisory approach to examinations during the pandemic; the FDIC’s tech lab, FIDTECH, announced a “tech...more

Goodwin

Financial Services Weekly Roundup: Treasury And SBA Codify Changes To PPP Flexibility Act

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In This Issue. The U.S. Department of the Treasury (Treasury) and the Small Business Administration (SBA) released an interim final rule to reflect changes made by H.R. 7010, the Paycheck Protection Program Flexibility Act,...more

Sheppard Mullin Richter & Hampton LLP

Fed’s Vice Chair for Supervision Proposes a Deregulatory Approach to Limit the Scope of “Matters Requiring Attention” used in Bank...

A January proposal to give banks compliance slack floated by a high-ranking Federal Reserve Board (“FRB”) official has not yet gained the traction its supporters had hoped for. In remarks before the American Bar Association...more

Moore & Van Allen PLLC

Enhancing Transparency in the Agencies’ Approach to BSA/AML Examinations

Last month the Financial Crimes Enforcement Network (FinCEN) and the federal bank regulators issued a Joint Statement aimed at improving transparency into their risk-focused examination and supervision of banks’ compliance...more

Nutter McClennen & Fish LLP

Nutter Bank Report, December 2018

FDIC Approves 3-Year Phase-In for Adverse Effects on Capital from CECL - The FDIC has approved a final rule that will provide banks with the option to phase in over a three-year period the day-one adverse effects on...more

Nutter McClennen & Fish LLP

Nutter Bank Report, September 2018

Federal Banking Agencies Issue Joint Statement on the Role of Supervisory Guidance - The federal banking agencies, along with the CFPB and the NCUA, have issued a joint statement clarifying the role of supervisory...more

Ballard Spahr LLP

OCC Updates Examiner Guidance on “Deposit-Related Credit”

Ballard Spahr LLP on

On September 12, 2018, the Office of the Comptroller of the Currency (the “OCC“) released its first update to the “Deposit-Related Credit” booklet of the Comptroller’s Handbook (the “DRC Booklet“) since its March 2015...more

Nutter McClennen & Fish LLP

Nutter Bank Report, August 2018

Headlines - ...OCC to Begin Accepting Applications for Bank Charters for Fintech Companies ...Agencies Issue Rules Implementing 18-Month Exam Cycles for Community Banks...more

Vedder Price

Wells Fargo’s CAMELS Rating Leaked

Vedder Price on

The Wall Street Journal recently reported that the management component of the CAMELS rating for Wells Fargo Bank, NA had been downgraded to a “3” during 2017. A “3” rating of management means that the capabilities of...more

Ballard Spahr LLP

New OCC FAQs on third-party relationships highlight bank arrangements with fintech companies and marketplace lenders

Ballard Spahr LLP on

The Office of the Comptroller of the Currency has issued a new bulletin (2017-21) containing fourteen frequently asked questions to supplement OCC Bulletin 2013-29 entitled “Third-Party Relationships: Risk Management...more

BakerHostetler

[Webinar] The State of Mortgage Examinations - June 29th, 1:00p.m. EDT

BakerHostetler on

With changing federal regulations, all eyes naturally focus on the Consumer Financial Protection Bureau’s (CFPB) latest activity. However, the CFPB will conduct less than 30 origination examinations by the end of this year,...more

Katten Muchin Rosenman LLP

Federal Banking Agencies Expand Number of Banks Qualifying for 18-Month Examination Cycle

On February 19, federal banking agencies increased the number of small banks and savings associations eligible for an 18-month examination cycle rather than a 12-month cycle. The changes are intended to reduce regulatory...more

Bilzin Sumberg

Tougher Scrutiny on Cybersecurity at Banks in 2016

Bilzin Sumberg on

Cybersecurity has been a focus as part of bank exams for years. Now the Federal Deposit Insurance Corp. (FDIC) is increasing its scrutiny of banks’ cybersecurity practices to ensure that the issue is getting appropriate...more

Katten Muchin Rosenman LLP

Federal Reserve Issues Guidance on Waiving of Examinations Prior to Membership or Merger Into a State Member Bank

On October 13, the Board of Governors of the Federal Reserve System (Board) issued guidance that applies to insured depository institutions that are seeking to become state chartered member banks of the Federal Reserve System...more

K&L Gates LLP

New York Department of Financial Services Unveils “New Cyber Security Examination Process”: Five Key Takeaways

K&L Gates LLP on

On December 10, 2014, Superintendent Benjamin Lawsky of the New York Department of Financial Services (the “DFS”) announced a “New Cyber Security Examination Process” (the “New Examination Process”) for New York-chartered and...more

Davis Wright Tremaine LLP

FFIEC Releases Revised BSA/AML Examination Manual

The Federal Financial Institutions Examination Council (FFIEC) has released its revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The revisions clarify supervisory expectations and incorporate...more

Ballard Spahr LLP

CFPB’s Ombudsman’s Office issues third annual report

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Last week, the CFPB’s Ombudsman’s Office issued its third annual report covering the Office’s activities during fiscal year 2014 (October 1, 2013 through September 30, 2014). The role of the Ombudsman’s Office is to assist in...more

Ballard Spahr LLP

OCC steps up SCRA focus in exams

Ballard Spahr LLP on

As we have been reporting, the CFPB has made the Servicemembers Civil Relief Act (SCRA) a major focus and instructs its examiners to look at SCRA compliance during examinations. The OCC has also stepped up its focus on SCRA...more

Troutman Pepper

‘Heightened Standards’ For Large Banks: OCC Proposed Guidelines

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On January 16, 2014, the Office of the Comptroller of the Currency (OCC) released a proposal seeking comment on guidelines that would establish minimum standards of governance, risk management and board independence for...more

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