The proposal would establish stricter oversight of certain transactions and responds to concerns that large asset managers may be exerting influence on FDIC-supervised institutions. On July 30, 2024, the Board of...more
On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more
The Situation: The Federal Deposit Insurance Corporation (FDIC) has issued a final rule which substantively changes the scope and expectations for Insured Depository Institution (IDI) resolution plans (FDIC Final Resolution...more
The proposal seeks to make executive compensation arrangements more sensitive to risk and would require complex risk management programs to ensure compliance....more
The Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency recently announced proposals to update their approaches to evaluating bank mergers and other business combinations under the Bank Merger...more
On January 29, 2024, the OCC issued a proposed policy statement[1] describing the general principles it uses to evaluate applications for approval of transactions under the Bank Merger Act (“BMA”), principally bank mergers,...more
Regulatory Developments - OCC Solicits Research on Implications of Financial Technology for Banking - On July 25, the OCC is seeking academic and policy-focused research on the impact that fintech and non-bank...more
On May 5, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board (“FRB”) and the Office of the Comptroller of the Currency (“OCC”) (together, the “Agencies”) issued a notice of proposed rulemaking to...more
On March 22, the Federal Reserve Board issued a Notice of Proposed Rulemaking (“NPR”) that will be joined by the Federal Deposit Insurance Corporation, National Credit Union Administration and the Office of the Comptroller of...more
Now that the pandemic’s “social distancing” is lessening, we hope you are all able to gather with friends and family this Thanksgiving. As we do the same, we wanted to count our blessings as we review the year. This year, we...more
Federal Banking Agencies Issue Guide for Community Banks on Conducting Due Diligence on Fintech Companies - On August 27, 2021, the federal banking agencies (Federal Reserve, FDIC, and OCC) published “Conducting Due...more
On January 12, 2021, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) published a Notice of Proposed...more
The Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) recently announced a “Notice of Proposed...more
Federal Reserve Revises Framework for Determining Control of a Banking Organization The Federal Reserve has adopted a final rule to simplify and clarify its regulations for determining control of a banking organization for...more
On January 30, 2020, five federal regulatory agencies, the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation (“FDIC”), the Federal Reserve Board, the Office of the Comptroller of the Currency,...more
While banks, community groups, and regulators all seem to agree that there is a need to reform the Community Reinvestment Act (the “CRA”), which was signed into law by Jimmy Carter back in 1977 and hasn’t received a major...more
On November 18 and 19 of this week, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation issued Advanced Notices of Proposed Rulemaking (ANPRs) to clarify how state interest rate caps...more
On November 19, the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking (FDIC Notice) setting forth a proposed rule that, if ultimately adopted, would confirm that the “valid-when-made” doctrine...more
The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking (Notice) that would affirm that when a national bank or savings association sells, assigns, or...more
On Monday, September 9, 2019, a group of 28 housing, consumer protection and community development organizations issued a letter to the Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency and...more
On August 20, 2019, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) approved amendments to the regulations implementing Section 13 of the Bank Holding Company Act,...more
On February 8, the OCC, the Federal Reserve Board and the FDIC issued a notice of proposed rulemaking that would provide a simplified measure of capital adequacy for qualifying community banking organizations consistent with...more
On November 21, 2018, the Federal Reserve, Office of Comptroller of the Currency and the FDIC jointly published a notice of proposed rulemaking (the “NPR”) to provide an alternative capital system for qualifying banking...more
Agencies Propose Simplifying Regulatory Capital Rules - On September 27, 2017, the Federal Deposit Insurance Corporation, the Federal Reserve Board and the Office of the Comptroller of the Currency announced a proposed...more
The US Federal Reserve Board, the Farm Credit Administration, the FDIC, the National Credit Union Administration and the OCC issued a joint notice of proposed rulemaking to implement provisions of the Biggert-Waters Flood...more