News & Analysis as of

FRB Risk Management

Goodwin

FRB Fines Utah Prepaid Debit Card Company $44 Million for Unfair and Deceptive Practices

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O​​​​​​​n July 19, 2024, the Federal Reserve Board announced it had fined a Utah-based company that offers prepaid debit cards $44 million for alleged unfair and deceptive practices as well as an alleged deficient consumer...more

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

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The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

Patomak Global Partners

Stress Test Results Keep Risk Management Capabilities in Focus

Situation Overview: The Federal Reserve Board (FRB) uses the stress tests as a key supervisory tool to explore risks across large banks. This year’s results quantified the impact to banks under multiple new scenarios,...more

Cadwalader, Wickersham & Taft LLP

Vice Chair Barr Speaks on Liquidity Risk Management and Preparation for Use of Discount Window

Last Friday, Michael Barr, the Federal Reserve Board’s (“FRB”) Vice Chair for Supervision, delivered remarks to the ECB Forum on Banking Supervision in Frankfurt, Germany entitled The Importance of Effective Liquidity Risk...more

Cadwalader, Wickersham & Taft LLP

Fed Issues FAQs Clarifying That Credit-Linked Notes Can Serve as Valid Capital Relief Tools for U.S. Banks

On September 28, the Federal Reserve Board (“FRB”) posted three new FAQs to its website regarding Regulation Q (Capital Adequacy of Bank Holding Companies, Savings and Loan Holding Companies, and State Member Banks). The FAQ...more

Morrison & Foerster LLP

Federal Reserve Issues Guidance on Novel Activities, Including Bank-Fintech Partnerships

On August 8, 2023, the Board of Governors of the Federal Reserve System (FRB) issued two Supervision and Regulation Letters (“SR Letters”) that provide guidance on the agency’s supervision of novel activities and the process...more

Latham & Watkins LLP

Agencies Issue Guidance for Banking Organizations on Managing Risk in Third-Party Relationships

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The guidance outlines principles and key considerations for banking organizations as they navigate risks associated with third parties, including fintechs. On June 6, 2023, the Federal Deposit Insurance Corporation...more

Sheppard Mullin Richter & Hampton LLP

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

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

Buchalter

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

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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

Cadwalader, Wickersham & Taft LLP

Banking Agencies Finalize Interagency Guidance on Third-Party Risk Management

On June 6, the three Federal bank regulatory agencies (the Federal Reserve Board (“FRB”), Federal Deposit Insurance Corporation (“FDIC”) and Office of the Comptroller of the Currency (“OCC”)), issued final interagency...more

Orrick, Herrington & Sutcliffe LLP

Agencies warn banks of crypto-asset liquidity risks

On February 23, the FDIC, Federal Reserve Board, and OCC released a joint statement addressing bank liquidity risks tied to crypto-assets. The agencies warned that using sources of funding from crypto-asset-related entities...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Announces Pilot Climate Scenario Analysis Exercise Details

Last week, the Federal Reserve Board (FRB) announced additional details on its pilot climate scenario analysis (CSA) involving six of the largest U.S. banks. The additional details include a Participant Instructions Document...more

Orrick, Herrington & Sutcliffe LLP

Fed announces climate scenario exercises

On January 17, the Federal Reserve Board provided additional details regarding its upcoming pilot climate scenario analysis exercise and the information on risk management practices that will be gathered from the program. ...more

Cadwalader, Wickersham & Taft LLP

FRB Proposes Climate-Related Financial Risk Management Principles

Recently, the Federal Reserve Board (“FRB”) proposed principles for climate-related financial risk management for large financial institutions. The proposed guidance is open for comment until 60 days after publication in the...more

Goodwin

CFPB Withdraws Proposal to Delay Debt Collection Final Rules

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In This Issue. The Consumer Financial Protection Bureau (CFPB) withdrew its proposal to delay the Debt Collection Final Rules; the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - Class Action Against Lending Club and WebBank Headed to Defeat - On Monday, January 31, 2017, a federal district court in the Southern District of New York granted a motion to...more

Dechert LLP

US Federal Reserve Board Begins the Process of Regulating Insurance Companies

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Nearly six years after the adoption of Dodd-Frank’s Title I, which provides for the regulation by the Board of Governors of the Federal Reserve System (Board) of non-bank financial companies – such as insurance companies,...more

Holland & Knight LLP

FFIEC’s Cybersecurity Assessment Tool: Guidance for CEOs and Boards - Senior Management and Boards Should Be Actively Addressing...

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The Federal Financial Institutions Examination Council (FFIEC) released a Cybersecurity Assessment Tool (CAT) on June 30, 2015, to assist organizations in identifying cyber risks and assessing their cybersecurity...more

Goodwin

FRB Issues Guidance on Managing Risks from the Use of Third Party Service Providers

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The FRB issued guidance on managing outsourcing risks (the “Guidance”), intended to highlight the potential risks arising from the use of third-party service providers, describe the components of an appropriate service...more

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