News & Analysis as of

Financial Institutions Office of the Comptroller of the Currency Enforcement Actions

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions for May 2024

On May 23, the OCC released a list of recent enforcement actions against national banks, federal savings associations, and individuals affiliated with such entities (defined as institution-affiliated parties, or IAPs). The...more

Venable LLP

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

Venable LLP on

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

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - March 2024 - 2

Editor's Note - 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,...more

The Volkov Law Group

Sterling Bank’s ex-General Counsel hit with OCC Cease-and-Desist over Longstanding BSA/AML Shortcomings

The Volkov Law Group on

The Treasury Department’s Office of the Comptroller of the Currency (“OCC”) has taken action against the former General Counsel of Michigan-based Sterling Bank and Trust in the agency’s latest action against an individual...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 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

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

Jenner & Block on

As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Adams and Reese LLP

OCC Publishes Revised Examination Procedures Addressing Telephone Consumer Protection Act

Adams and Reese LLP on

On November 1, 2023, the Office of the Comptroller of the Currency (OCC) published a revised interagency examination procedure to address updates to the federal Telephone Consumer Protection Act (TCPA). Although TCPA...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2023 # 2

Troutman Pepper on

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Finance Services industry over the past week...more

Ballard Spahr LLP

Minnesota Bankers Association and Lake Central Bank sue FDIC over NSF fee guidance

Ballard Spahr LLP on

A complaint filed on July 20, 2023 in Minnesota federal court seeks declaratory and injunctive relief under the Administrative Procedures Act (APA) against defendants Federal Deposit Insurance Corporation (FDIC) and Chairman...more

Ballard Spahr LLP

Former Bank Compliance Chief Seeks Appellate Review of OCC Administrative Enforcement Proceeding Dismissal

Ballard Spahr LLP on

In an unusual move, Laura Akahoshi, former Rabobank (the “Bank”) Chief Compliance Officer (“CCO”), filed on July 6, 2023 an opposition to the Office of the Comptroller of the Currency’s (“OCC”) dismissal of its own...more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions

On March 17, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals currently and formerly affiliated with such entities. ...more

Polsinelli

Silicon Valley Bank Receivership

Polsinelli on

1. What happened Friday? a. The California Department of Financial Protection and Innovation closed Silicon Valley Bank (SVB) and appointed FDIC as receiver....more

Sheppard Mullin Richter & Hampton LLP

OCC Revises Policies and Procedures for Civil Money Penalties

On November 29, the OCC released a revised Policies and Procedures Manual relating to the assessment of civil money penalties (“CMP Matrix”), which will be effective as of January 1, 2023. The CMP Matrix is a reference guide...more

Oberheiden P.C.

OCC Enforcement Defense Strategies

Oberheiden P.C. on

Because failing to comply with the legal obligations imposed by the Bank Secrecy Act (BSA) can subject national banks or other financial institutions to significant penalties and considerable hardship, it is paramount for...more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2022

Headlines: ..OCC Publishes Security Standards for Video Teleconferencing With Agency Staff ..CFPB Imposes Civil Penalty and Customer Refunds for Authorized-Positive Overdraft Fees ..Treasury Department Recommends...more

Steptoe & Johnson PLLC

Computer-Security Incident Rule Creates New Notification Requirements for Banking Organizations and Bank Service Providers

Steptoe & Johnson PLLC on

On November 18, 2021, the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System (FRB), and the Office of the Comptroller of the Currency (OCC) issued a joint final rule (the...more

Sheppard Mullin Richter & Hampton LLP

CFPB, DOJ and OCC Take Action Against National Bank for Alleged Redlining

The CFPB and DOJ, in cooperation with the OCC, filed a complaint and proposed consent order last week in the Western District of Tennessee against a national bank alleging that the bank violated the Fair Housing Act (FHA),...more

Bilzin Sumberg

An Opportune Time For Financial Institutions to Review Their Fair Lending Procedures

Bilzin Sumberg on

At the beginning of his term, President Biden declared that his administration would make it a policy to eliminate “racial bias and other forms of discrimination in all states of home-buying and renting.”...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

Manatt, Phelps & Phillips, LLP

DOJ, OCC Announce Major Settlement of Fair Lending Allegations

In the largest fair lending enforcement action in several years, the Department of Justice (DOJ) and the Office of the Comptroller of the Currency (OCC) on August 30 announced simultaneous settlements with a national banking...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

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

Goodwin on

In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...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

Goodwin

Financial Services Weekly Roundup: The Supreme Court Strikes Back On Single Director Leadership Structures

Goodwin on

In This Issue. The U.S. Supreme Court struck down the single director leadership structure of the Consumer Financial Protection Bureau (CFPB) in a ruling that could have far-reaching implications for the CFPB and other...more

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