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Financial Services Industry Office of the Comptroller of the Currency New Guidance

Troutman Pepper

FDIC and OCC Finalize New Guidelines on Bank Mergers

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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

Cadwalader, Wickersham & Taft LLP

February 2024 Regulatory Round-Up

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

Troutman Pepper

OCC Announces Adjusted Maximum Civil Monetary Penalties for 2024

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On January 8, the Office of the Comptroller of the Currency (OCC) announced adjustments to the maximum amount of each civil money penalty (CMP) within its jurisdiction. The 2015 Adjustment Act requires federal agencies with...more

Ballard Spahr LLP

OCC issues guidance on managing risks associated with “buy now, pay later” lending

Ballard Spahr LLP on

The Office of the Comptroller of the Currency (OCC) has issued a bulletin (2023-37) that provides guidance on managing risks associated with “buy now, pay later” (BNPL) lending.  The BNPL loans addressed in the bulletin are...more

Latham & Watkins LLP

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

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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

Nutter McClennen & Fish LLP

Nutter Bank Report: August 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

Stinson LLP

New Interagency Policy Statement on CRE Loan Accommodations and Workouts

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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

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2023

The federal banking agencies have published new guidance to help banking organizations manage risks associated with third-party relationships, including relationships with financial technology (fintech) companies. The new...more

Jenner & Block

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

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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

Goodwin

Overdraft Protection Programs: Risk Management Practices

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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

Cadwalader, Wickersham & Taft LLP

OCC and FDIC Provide Supervisory Guidance on Certain Overdraft Practices

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

Orrick, Herrington & Sutcliffe LLP

OCC revises guidance on change in bank control

On February 16, the OCC released an updated version of the “Change in Bank Control” booklet of the Comptroller’s Licensing Manual. According to OCC Bulletin 2023-7, the revised licensing booklet—which outlines OCC policies...more

Orrick, Herrington & Sutcliffe LLP

OCC updates fair lending booklet of Comptroller’s Handbook

On January 12, the OCC released a revised version of the “Fair Lending” booklet of the Comptroller’s Handbook. The revised booklet replaces the prior booklet issued in January 2010. ...more

Polsinelli

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

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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

Goodwin

FDIC Seeks Comment on Supervisory Approach to Examinations During Pandemic

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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

CFPB Grants No-Action Letter for Proposed Small-Dollar Credit Product

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In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more

Goodwin

SEC Charges Trust Company With Operating Unregistered Investment Companies

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SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more

Goodwin

Financial Services Weekly Roundup: Gone Phishing – The SEC’s OCIE Addresses Ransomware Attacks

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In This Issue. The Securities and Exchange Commission (SEC) adopted amendments to its exemptive applications procedures under the Investment Company Act of 1940, as amended (the 1940 Act) and proposed to amend Form 13F to...more

Goodwin

Financial Services Weekly Roundup: New Rules, Amendments And More Amid Coronavirus Outbreak

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In This Issue. The ongoing global outbreak of the coronavirus (COVID-19) continues to grow in scale and scope. In response, federal financial regulators are continuing efforts to bring regulatory relief to promote stability...more

Goodwin

Financial Services Weekly News: Financial Regulators Respond To Coronavirus Outbreak

Goodwin on

In This Issue. The ongoing global outbreak of the coronavirus (COVID-19) continues to grow in scale and scope, creating public health and humanitarian challenges worldwide. Global economies are also being impacted. Federal...more

Goodwin

Financial Services Weekly News: FDIC Releases Guide To Connect Fintechs With Banks

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In This Issue. The Federal Deposit Insurance Corporation (FDIC) released a new guide to help financial technology companies and others partner with banks; the Financial Industry Regulatory Authority (FINRA) announced that it...more

Bradley Arant Boult Cummings LLP

Is the Bank Open? Federal Agencies Clarify Regulatory Requirements for Banking Hemp

On December 3, several federal agencies issued guidance (Guidance) that, by its terms, “provide[s] clarity” regarding “the regulatory requirements under the Bank Secrecy Act (BSA) for banks providing services to hemp-related...more

Ballard Spahr LLP

Banking Regulators Ease SAR Reporting Requirements Applied to Hemp-Related Businesses

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On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more

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