News & Analysis as of

Financial Institutions Office of the Comptroller of the Currency Consent Order

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2024

OCC Requests Public Comments on Proposed Bank Merger Policy Statement and Rules The OCC has proposed a new policy to increase the transparency of the standards that the agency applies to review business combinations involving...more

McGlinchey Stafford

Are Financial Institutions’ Consultants and Vendors Compromising Their Privileges?

McGlinchey Stafford on

A recent decision from the United States District Court for the Eastern District of Texas should trigger alarm bells for financial institutions’ in-house counsel. The court held that the bank involved had waived any privilege...more

Kaufman & Canoles

Credit Union Client Alert – Wells Fargo Must Pay $250 Million Fine

Kaufman & Canoles on

The Office of the Comptroller of the Currency (OCC) issued a $250 million civil penalty against Wells Fargo Bank, NA for flaws in the bank’s home loan loss mitigation program. In addition, the OCC issued a cease-and-desist...more

Goodwin

SBA Implemented Changes to PPP as a Part of American Rescue Plan Act

Goodwin on

In this Issue. The federal bank regulatory agencies announced that the temporary change to the supplementary leverage ratio for depository institutions will expire as scheduled on March 31, 2021; the Small Business...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

Goodwin on

In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

Goodwin

SEC Adopts Broad Exempt Offering Reforms

Goodwin on

In the News. The Securities and Exchange Commission (SEC) adopted broad exempt offering reforms; the Department of Labor (DOL) finalized a rule, with significant revisions from the original proposal, on ESG investments; the...more

Balch & Bingham LLP

OCC Issues $400 Million Civil Penalty in Consent Order with Citibank Over Risk and Data Governance

Balch & Bingham LLP on

On October 7, 2020, The Office of the Comptroller of the Currency (“OCC”) announced that it had assessed a $400 million civil penalty against Citibank, N.A. regarding alleged deficiencies in it enterprise-wide risk management...more

WilmerHale

Recent OCC Actions Focus Attention on Financial Crime Controls for Cryptocurrency Custody Businesses

WilmerHale on

Two recent actions by the Office of the Comptroller of the Currency (OCC) - one enforcement action and one interpretive note - focus attention on the kinds of anti–money laundering (AML) controls needed for banks to custody...more

Ballard Spahr LLP

Former Bank General Counsel Enters into Consent Order Over Alleged AML Obstruction

Ballard Spahr LLP on

The Office of the Comptroller of Currency (“OCC”) issued an extraordinary announcement regarding the decision of a former bank general counsel – Daniel Weiss, formerly employed by Rabobank, N.A. – to enter into a Consent...more

Goodwin

Financial Services Weekly News - March 2017

Goodwin on

Editor's Note - In This Issue. The New York Department of Financial Services issued its highly anticipated cybersecurity regulation in its final form, the Securities and Exchange Commission (SEC) issued updated guidance...more

Goodwin

Financial Services Weekly News - January 2017

Goodwin on

Editor's Note - In This Issue. The NYDFS revised its proposed cybersecurity regulations, the FDIC sought comment on its new de novo bank deposit insurance handbook, federal banking agencies finalized streamlined call...more

Morrison & Foerster LLP

CFPB Levies Largest Civil Money Penalty in Agency History, Alleges “Abusive” Conduct

On September 8, 2016, the Consumer Financial Protection Bureau (CFPB or “Bureau”), the Office of the Comptroller of the Currency (OCC), and the City and County of Los Angeles entered into a Consent Order with Wells Fargo...more

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