News & Analysis as of November 19, 2024

Office of the Comptroller of the Currency

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The Federal Deposit Insurance Corporation is a United States federal agency created in 1933 in response to widespread bank failures in the 1920s and early 1930s. The FDIC's mission is to maintain stability and consumer confidence in the United States banking system by insuring deposits, monitoring the health of financial institutions and managing receiverships. less -

Nutter Bank Report: October 2024

Nutter McClennen & Fish LLP on 10/31/2024

The CFPB has approved a final rule that requires banks and certain other financial services providers to share a consumer’s personal financial data with another provider at the consumer’s request. The CFPB’s Personal...more

FDIC, OCC and Justice Department update bank merger guidelines

Ballard Spahr LLP on 9/26/2024

The FDIC, the OCC and the Justice Department earlier this month issued updated standards for bank mergers. The three agencies acted separately, although officials noted that they had worked with the other agencies involved....more

FDIC and OCC Finalize New Guidelines on Bank Mergers

Troutman Pepper on 9/19/2024

Yesterday, both the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) finalized new guidelines regarding bank mergers. According to the agencies, these updates aim to enhance...more

Crystal Clear: New Guide on Third-Party Risk Management for Community Banks - and Others

Venable LLP on 5/14/2024

It is no secret that the Federal Reserve, the FDIC, and the OCC have zeroed in on banks' use of third parties for products, services, and other operations, the risks those arrangements may pose, and banks' responsibility to...more

February 2024 Regulatory Round-Up

Cadwalader, Wickersham & Taft LLP on 2/23/2024

As February already begins to wind down and all of us are wondering what we might have missed so far this year, here is a round-up of additional regulatory activities in financial services...more

Banking and Consumer Regulatory Digest - February 2024

Davis Wright Tremaine LLP on 2/19/2024

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Promissory Notes - Banking & Finance Insights: V 4, Issue 1, January 2024

Spilman Thomas & Battle, PLLC on 1/29/2024

OCC Issues Guidance on ‘Buy Now, Pay Later’ Lending - “The guidance notes that banks should maintain underwriting, repayment terms, pricing, and safeguards that minimize adverse customer outcomes and should ensure that...more

OCC Issues Policy Guidance on Venture Loans

Latham & Watkins LLP on 11/29/2023

The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in venture lending. On November 1, 2023, the Office of the Comptroller of the Currency...more

OCC, FRB, and FDIC Finalize Joint Principles for Climate-Related Financial Risk Management

Latham & Watkins LLP on 11/8/2023

Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more

Agency Guidelines Confirm That Climate-Related Financial Risk Is Real

Holland & Knight LLP on 11/6/2023

The U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corp. (FDIC) (collectively, the Agencies) on...more

Nutter Bank Report: August 2023

Nutter McClennen & Fish LLP on 8/31/2023

A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more

New Interagency Policy Statement on CRE Loan Accommodations and Workouts

Stinson LLP on 7/26/2023

On June 29, 2023, a new interagency Policy Statement (the Statement) was issued relating to commercial real estate (CRE) loan accommodations and workouts. The Statement is relevant to all financial institutions governed by...more

Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

Hudson Cook, LLP on 7/5/2023

On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more

Bank Regulators Issue Guidance for Third-Party Risk Management

Goodwin on 7/3/2023

On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...more

Client Alert: Bank-Fintech Partnerships Update: Banking Agencies Finalize Key Risk Management Guidance

Jenner & Block on 6/16/2023

On June 6, 2023, federal banking agencies issued final Interagency Guidelines on Third-Party Relationships detailing their expectations for banks in establishing risk management practices with third-parties—including...more

FDIC, FRB & OCC Issue Final Guidance on Risk Management for Third-Party Relationships

Sheppard Mullin Richter & Hampton LLP on 6/12/2023

On June 6, the FDIC, FRB & OCC issued final interagency guidance intended to assist their respective supervised banking organizations in identifying and managing risks associated with third-party relationships and in...more

FDIC, FRB & OCC Issue Interagency Guidance on Third-Party Relationships: Risk Management

Buchalter on 6/9/2023

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

Overdraft Protection Programs: Risk Management Practices

Goodwin on 5/1/2023

Regulatory Developments - Overdraft Protection Programs: Risk Management Practices - On April 26, the OCC issued guidance in OCC Bulletin 2013-12, “Overdraft Protection Programs: Risk Management Practices,” to...more

OCC and FDIC Provide Supervisory Guidance on Certain Overdraft Practices

Cadwalader, Wickersham & Taft LLP on 4/28/2023

The Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) (collectively, the “Agencies”) provided supervisory guidance this week on certain overdraft practices. Of particular...more

Nutter Bank Report: June 2022

Nutter McClennen & Fish LLP on 6/29/2022

Headlines - ..FDIC Proposes Substantial Increase in Deposit Insurance Assessment Rates ..Federal Reserve Releases New CECL Implementation Tool: Expected Losses ..Estimator OCC Report Highlights Risks Facing the Federal...more

Federal Banking Regulators Issue New Guidance for Complying with 36 Hour Cybersecurity Incident Reporting Requirement

Polsinelli on 4/1/2022

On March 29, 2022, federal banking regulators issued important guidance for how banking organizations can comply with the upcoming requirement to notify regulators within 36 hours of ransomware or other disruptive...more

US Regulators Raise Expectations of Third-Party Risk Management

Mitratech Holdings, Inc on 12/14/2021

It takes something significant for all the US Banking Regulators – the Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) – to come together to pool...more

Agencies Release Guide for Community Banks Conducting Due Diligence on Fintech Companies

Goodwin on 9/23/2021

In August 2021, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Board of Governors of the Federal Reserve System (the Federal Reserve and, collectively with the...more

FFIEC Updates Guidance to Financial Institutions for Authentication and Access

Cozen O'Connor on 9/15/2021

The Federal Financial Institutions Examination Council (FFIEC), an interagency body of leading financial regulators, including the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency,...more

FDIC Seeks Comment on Supervisory Approach to Examinations During Pandemic

Goodwin on 8/20/2021

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

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