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Office of the Comptroller of the Currency Risk Assessment Risk Management

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

McGlinchey Stafford

Bank Partnerships in an Evolving World

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Financial institutions have utilized service providers for a multitude of purposes over many years. The use of service providers has not historically been a controversial issue, and financial institutions have always had an...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

Ballard Spahr LLP on

On May 3, 2024, 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”) jointly released the...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

NAVEX

How to Build a Good Risk Assessment Process

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Risk assessments are one of the most important tasks a compliance officer performs – and also one of the most confounding. How do you keep assessing your organization’s risks in a disciplined, methodical manner, when the...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

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

Goodwin

Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities

Goodwin on

Regulatory Developments - Agencies Issue Joint Statement on Liquidity Risks Resulting from Crypto-Asset Market Vulnerabilities - On February 23, the Federal Reserve, FDIC and OCC (the Agencies) issued a “Joint...more

Latham & Watkins LLP

Acting Comptroller Confronts “Too Big to Manage” Issue

Latham & Watkins LLP on

The Acting Comptroller of the OCC discussed the limits of large bank manageability and the steps that regulators can take to address the risks posed by size and complexity. On January 17, 2023, Acting Comptroller of the...more

Latham & Watkins LLP

Banking Regulators Issue Joint Statement on Crypto Risks

Latham & Watkins LLP on

Banking organizations should ensure appropriate risk management, but regulators are skeptical of certain crypto activities as principal. On January 3, 2023, the Board of Governors of the Federal Reserve System (Federal...more

Cadwalader, Wickersham & Taft LLP

OCC Issues Its Semiannual Risk Perspective

The Office of the Comptroller of the Currency (“OCC”) issued its Semiannual Risk Perspective for Spring 2022 on June 23. This was the same day the Federal Reserve released the results of its stress test for large bank holding...more

Goodwin

FinCEN Warns Against Evasion of Russian Sanctions

Goodwin on

In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more

BCLP

Vetting FinTechs as Business Risk Partners: OCC Bulletin

BCLP on

Innovation is a key to competitive advantage and keeping pace with consumer digital banking preferences. Increasingly, banks are engaging the services of fintech’s who can deliver certain information and services in a more...more

Goodwin

FDIC Seeks Comment on Supervisory Approach to Examinations During Pandemic

Goodwin on

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

Moore & Van Allen PLLC

OCC Releases Bulletin on Fraud Risk Management Principles

In the aftermath of sales practices, the Office of the Comptroller of the Currency (OCC) recently published a bulletin on fraud risk management principles that are applicable to all federally chartered financial institutions....more

Manatt, Phelps & Phillips, LLP

OCC Highlights Areas of Risk, Including Fintech

A recently released report from the Office of the Comptroller of the Currency (OCC) identified key areas of risk that pose a threat to the safety and soundness of the federal banking system....more

Ballard Spahr LLP

OCC Report: Same Threats, Different Season

Ballard Spahr LLP on

OCC Identifies AML/BSA and Cyber Threats as Elevated Risks Facing Banks - Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses...more

Troutman Pepper

OCC Establishes New Third-Party Risk Management Expectations, Including for Bank Relationships With Marketplace Lenders

Troutman Pepper on

The bulletin requires relationships between banks and marketplace lenders to be treated with the same rigor of due diligence and ongoing oversight as other relationships with third parties. On January 24, the Office of...more

Bass, Berry & Sims PLC

New York and Feds Leading the Charge on Financial Institution Cybersecurity Regulations

Bass, Berry & Sims PLC on

Both federal and state officials recently proposed new regulations aimed at the financial sector in an effort to promote protection against high-impact technology failures and cyberattacks...more

Patterson Belknap Webb & Tyler LLP

OCC’s Cybersecurity Regulatory Expectations: A Call to Action

Not surprisingly, cybersecurity remains a top examination priority for the Comptroller of the Currency (“OCC”). And that means national banks and federal savings associations – and their leadership teams – should be prepared...more

Orrick - Finance 20/20

The Office of the Comptroller Provides Updated Guidance for Risk Assessment System

Orrick - Finance 20/20 on

On December 3, 2015, the Office of the Comptroller of the Currency (“OCC”) provided updated guidance for its risk assessment system (“RAS”). The guidance (i) clarifies the relationship between RAS and the Uniform Financial...more

Katten Muchin Rosenman LLP

OCC Announces Updated Risk Assessment System Guidance

On December 3, the Office of the Comptroller of the Currency (OCC) announced in Bulletin 2015 – 48 that it has updated its risk assessment system (RAS) guidance. These updates are reflected in the “Bank Supervision Process,”...more

Ballard Spahr LLP

FFIEC Tool Helps You Assess Cyber Risk

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The Federal Financial Institutions Examination Council (FFIEC) has released its long-awaited Cybersecurity Assessment Tool (Assessment) to help financial institutions identify the inherent risks faced by a company and...more

Manatt, Phelps & Phillips, LLP

OCC Report Highlights Wide Range of Potential Risks

Why it matters - The OCC’s most recent report on current key risks should be read by all banks, regardless of size or regulator, as a road map in preparing for the next examination. Few banks would ever admit they may...more

Troutman Pepper

Fear of Heights? OCC Adopts Heightened Standards for Risk Governance of Large Institutions

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Wasting no time in leaving summer behind, on September 2, 2014, the Office of the Comptroller of the Currency (OCC) adopted Final Guidelines, to be published soon in the Federal Register, establishing risk governance...more

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