News & Analysis as of

Risk Assessment Office of the Comptroller of the Currency Banks

Patomak Global Partners

OCC Expands Recovery Planning Requirements

Situation Overview: The Office of the Comptroller of the Currency (OCC) finalized revisions to Recovery Planning Guidelines, which substantively change the scope and expectations for recovery plans. What: The OCC is...more

Moore & Van Allen PLLC

OCC Issues Guidance Reminding Banks of Risks Associated with Refinancing Commercial Loans

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With the amount of commercial real estate loans scheduled for maturity over the next several years expected to increase significantly, there is accompanying heightened risk that some borrowers may be unable to replace their...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

Ballard Spahr LLP

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

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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

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2023

The federal banking agencies have published new guidance to help banking organizations manage risks associated with third-party relationships, including relationships with financial technology (fintech) companies. The new...more

Pillsbury Winthrop Shaw Pittman LLP

Bank-Fintech Partnerships and Fair Lending: Top Areas at Risk for Government Scrutiny

The Federal Deposit Insurance Corporation (FDIC) recently published a consent order issued against Cross River Bank that alleged the bank’s fair lending program’s noncompliance and weaknesses in its oversight of fintech...more

Skadden, Arps, Slate, Meagher & Flom LLP

Recent Actions by the Fed Show Its Continued Cautious Approach to Cryptoasset Activities by Supervised Institutions

In the past year, the Board of Governors of the Federal Reserve System (the Board) Biden administration officials, and other U.S. banking regulators have repeatedly voiced growing concerns about certain cryptoasset...more

Latham & Watkins LLP

Acting Comptroller Confronts “Too Big to Manage” Issue

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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

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

Cozen O'Connor

FFIEC Updates Guidance to Financial Institutions for Authentication and Access

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The Federal Financial Institutions Examination Council (FFIEC), an interagency body of leading financial regulators, including the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency,...more

Eversheds Sutherland (US) LLP

The OCC’s 2019 annual report addresses anti-money laundering risks for financial institutions

The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...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

Nutter McClennen & Fish LLP

Fintech in Brief: OCC Singles Out Financial Innovation as Special Risk Topic

On May 20, the OCC published its Semiannual Risk Perspective, Spring 2019 and singled out financial innovation and rapid developments in Fintech as a special topic in emerging risks to the banking industry. This is the first...more

Ballard Spahr LLP

OCC report identifies use of third-party service providers and consumer compliance as key risks for federal banking system

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Last week, the OCC released its Semiannual Risk Assessment for Fall 2017 highlighting credit, operational, and compliance risks to the federal banking system. ...more

Steptoe & Johnson PLLC

Proposed Regulatory Updates Will Require Increased Analysis of New Loans to Determine if Different Risk Weight Exposures Apply

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On September 27, 2017, the principal federal banking agencies, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, released a Notice of...more

Troutman Pepper

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

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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

Patterson Belknap Webb & Tyler LLP

Rock and a Hard Place: Banks In Search of Compliance Amid Diverging Regulatory Regimes

Last year was the first that national banks and federal savings associations subject to supervision by the Office of the Comptroller of the Currency (“OCC”) were armed with a sense of the agency’s regulatory expectations when...more

Bass, Berry & Sims PLC

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

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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

Locke Lord LLP

OCC Releases Semiannual Risk Perspectives Report

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On December 16, 2015, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspectives report for the fall of 2015. The OCC’s Semiannual Risk Perspective report “addresses key issues facing banks,...more

Ballard Spahr LLP

OCC Report Identifies Risks to Banks, Sets Supervisory Priorities

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A new report issued by the federal Office of the Comptroller of the Currency (OCC) identifies top safety and soundness risks to national banks and federal savings associations, as well as OCC supervisory priorities for the...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

Manatt, Phelps & Phillips, LLP

OCC Report Lists Key Risks For Review In Upcoming Examinations

Highlighting the operational, strategic, and compliance risks confronting financial institutions, the Office of the Comptroller of the Currency (OCC) published its “Semiannual Risk Perspective” report in late June based on...more

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