News & Analysis as of

Office of the Comptroller of the Currency Recordkeeping Requirements

Orrick, Herrington & Sutcliffe LLP

OCC seeks input on LCR and NSFR reporting and recordkeeping requirements

On April 16, the OCC released a request for comment on proposed revisions to its “Reporting and Recordkeeping Requirements Associated with Liquidity Coverage Ratio: Liquidity Risk Measurement, Standards, and Monitoring” to...more

The Volkov Law Group

JP Morgan Fined $348 Million for Deficient Record-Keeping

The Volkov Law Group on

Regulators with the Federal Reserve and the Office of the Comptroller of the Currency (“OCC”) have fined JP Morgan Chase & Co. a combined total of $348.2 million over the bank’s failure to monitor client trading activities...more

Davis Wright Tremaine LLP

CFTC Division of Enforcement, FY 2023: A Year in Review and Looking Ahead

On November 7, 2023, the Division of Enforcement ("Division") of the United States Commodity Futures Trading Commission ("CFTC") released its annual report of the results of its enforcement efforts, announcing that it had...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

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Goodwin

Agencies Approve Final Rule: Computer-Security Incident Notification

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Board of Governors of the Federal Reserve System (together, the Agencies) issued a final rule...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

Perkins Coie

Blockchain Week in Review - December 2020 #3

Perkins Coie on

CFTC Releases Digital Asset Primer - On December 17, 2020, the CFTC announced a 36-slide Digital Assets Primer. The Digital Assets Primer seeks to build on a prior 2017 release that focused on virtual currencies. This...more

Goodwin

OCC Finalizes “True Lender” Rule

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more

Jones Day

OCC Concludes That National Banks May Provide Cryptocurrency Custody Services

Jones Day on

The OCC sees holding the cryptographic access keys to control and transfer cryptocurrency as an "electronic corollary" of banking's traditional safekeeping methods. On July 22, 2020, the Office of the Comptroller of the...more

Sullivan & Worcester

OCC Gives Banks Keys to the Crypto Kingdom

Sullivan & Worcester on

On July 22, 2020, the Office of the Comptroller of the Currency (“OCC”) published an Interpretive Letter (the “Letter”) declaring that national banks and federal savings associations (collectively, “national banks”) may...more

A&O Shearman

Options Clearing Corporation Enters Into Settlements With SEC And CFTC Over Risk Management Policies

A&O Shearman on

On September 4, 2019, the Securities and Exchange Commission (“SEC”) and the Commodity Futures Trading Commission (“CFTC”) announced they had entered into settlements with Options Clearing Corporation (“OCC”) regarding its...more

Vedder Price

The OCC Speaks: How FinTech Applications Will Be Reviewed

Vedder Price on

On March 15, 2017, the Office of the Comptroller of the Currency (the “OCC”) published for comment a draft supplement to the OCC’s existing Comptroller’s Licensing Manual providing detail on how the OCC will evaluate national...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - Federal Reserve Board Announces Finalized Rule Adjusting the Board's Maximum Civil Money Penalties - On January 18, 2017, the Federal Reserve Board announced that it was adjusting...more

Winstead PC

Agencies Propose Incentive Compensation Rules for Financial Institutions

Winstead PC on

The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the U.S. Securities and Exchange Commission recently proposed new restrictions...more

Latham & Watkins LLP

Revised Rules on Dodd-Frank Incentive Compensation Requirements for Financial Institutions Proposed

Latham & Watkins LLP on

If adopted, the Proposed Rule would have a significant impact on compensation practices at covered institutions. On April 21, 2016, the National Credit Union Administration (the NCUA) issued a proposed rule regarding...more

Stinson - Corporate & Securities Law Blog

New Proposed Rules on Banker Incentive Compensation Released

The National Credit Union Administration, or NCUA, became the first of six Agencies to unveil a revised rule proposal under Section 956 of the Dodd-Frank Act: prohibiting incentive-based payment arrangements that the...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

The Federal Housing Administration Announces New Loan Limits for 2016 - On December 9, 2015, the Federal Housing Administration ("FHA") announced its schedule of loan limits for the 2016 calendar year. The new schedule,...more

Perkins Coie

Financial Services Bulletin: Action At Federal Agencies

Perkins Coie on

Federal Agencies Issue Enhanced Supplementary Leverage Ratio Final Rule for Largest Banking Organizations and Propose Update to Supplementary Leverage Ratio Rule - On Tuesday, April 8, 2014, the Board of Governors of...more

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