News & Analysis as of

Office of the Comptroller of the Currency Banking Sector Risk Management

Orrick, Herrington & Sutcliffe LLP

OCC announces enforcement actions for August 2024

On August 22, 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

Cadwalader, Wickersham & Taft LLP

Summer Regulatory Round-Up | July 2024

The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...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

Orrick, Herrington & Sutcliffe LLP

Fed, OCC, and FDIC release third-party risk management report for community banks

On May 3, the Fed, OCC, and FDIC (the regulators) released a report to help community banks assess their third-party relationship risk exposure. The report discusses key considerations in three areas: risk management,...more

Pillsbury - Global Sourcing Practice

Operational Resilience Requirements May Be Coming for Large U.S. Banks Soon

On March 12, 2024, Acting Comptroller of the Currency Michael Hsu indicated in a speech that regulations may soon be forthcoming that would be designed to bolster larger depository institutions’ ability to withstand...more

Orrick, Herrington & Sutcliffe LLP

OCC’s Hsu discusses bank fairness and effective compliance risk management

On March 25, the Acting Comptroller of the Currency, Michael J. Hsu, released a transcript of a speech on fairness and effective compliance risk management in banking, delivered at a banking association meeting. The speech...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024 - 3

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, specifically...more

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

Orrick, Herrington & Sutcliffe LLP

Acting Comptroller discusses bank liquidity risk

On January 18, OCC Acting Comptroller of the Currency, Michael J. Hsu, delivered remarks at an event held by Columbia University Law School on bank liquidity risk. Hsu highlighted the evolving nature of bank runs and urged...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Orrick, Herrington & Sutcliffe LLP

OCC releases enforcement actions (UPDATE)

On November 16, 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. Included is a cease and...more

Latham & Watkins LLP

OCC Issues Policy Guidance on Venture Loans

Latham & Watkins LLP on

The OCC outlines safety and soundness principles and appropriate risk management processes for its regulated institutions that engage in venture lending. On November 1, 2023, the Office of the Comptroller of the Currency...more

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Orrick, Herrington & Sutcliffe LLP

Regulators release final principles for climate-related financial risk management

On October 25, the Fed, OCC, and FDIC issued final interagency guidance titled Principles for Climate-Related Financial Risk Management for Large Financial Institutions. The principles are intended to help the largest...more

Moore & Van Allen PLLC

The Federal Reserve, FDIC and OCC Issue Final Guidance on Risk Management in Third-Party Relationships: Moore & Van Allen

On June 6, 2023, the Board of Governors of the Federal Reserve System (the Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC, and collectively with the...more

McGlinchey Stafford

Interagency Guidance on Risks Associated with a Third-Party Relationship

McGlinchey Stafford on

On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more

Hudson Cook, LLP

Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

Hudson Cook, LLP on

On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more

Goodwin

Bank Regulators Issue Guidance for Third-Party Risk Management

Goodwin on

On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...more

Cozen O'Connor

Final Interagency Guidance on Managing Risks Associated with Third-Party Relationships

Cozen O'Connor on

On June 6, 2023, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency and Federal Deposit Insurance Corp. (collectively, the “Agencies”) issued final interagency guidance that...more

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Morrison & Foerster LLP

Banking Agencies Issue Joint Third-Party Risk Management Guidance

On June 9, 2023, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) published final joint guidance on managing...more

K2 Integrity

Crypto in a Time of Uncertainty

K2 Integrity on

On 07 June 2023, K2 Integrity hosted a webinar on the state of cryptocurrency and digital assets in a rapidly evolving regulatory landscape. A discussion was held with Bryan Stirewalt, senior managing director at K2...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

Goodwin

Agencies Issue Final Guidance on Third-Party Risk Management

Goodwin on

Agencies Issue Final Guidance on Third-Party Risk Management - On June 6, the Federal Reserve, FDIC, and OCC issued final joint guidance (the Guidance) pertaining to banking organizations’ risk management of third-party...more

Venable LLP

Banking Agency Guidance on Third Party Relationships

Venable LLP on

Financial technology companies (fintechs) and other third parties in bank partnerships are routinely subject to scrutiny by their banking partner customers. The Federal Reserve System, the Federal Deposit Insurance...more

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