News & Analysis as of

Risk Management Banks Office of the Comptroller of the Currency

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

Banking Regulators’ Request for Information on Bank-Fintech Arrangements

On July 25, 2024, the Fed, the OCC and the FDIC (the “Banking Regulators”) released a “Request for Information on Bank-Fintech Arrangements Involving Banking Products and Services Distributed to Consumers and Businesses” (the...more

Ballard Spahr LLP

Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

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The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

Troutman Pepper

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

Troutman Pepper on

Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...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

Latham & Watkins LLP

OCC Proposes Updates to Large Bank Recovery Planning Guidelines

Latham & Watkins LLP on

OCC-supervised institutions with $100 billion or more in average total consolidated assets must be adequately prepared to mitigate severe financial and non-financial risks. ...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

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As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

Troutman Pepper

Federal Banking Agencies Issue New Guidebook for Community Banks Managing Third-Party Relationships

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On May 3, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency (collectively, the agencies) released a guidebook aimed at assisting...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

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

Ballard Spahr LLP

Acting Comptroller Hsu Highlights Latest Efforts of OCC in Elevating Financial Fairness

Ballard Spahr LLP on

On April 4, acting Comptroller of the Currency Michael J. Hsu provided his remarks for the second year in a row at the Just Economy Conference hosted by the National Community Reinvestment Coalition. He focused his remarks on...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

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

Jones Day

Final Climate Risk Guidance Ensures Supervisory Focus from Banking Agencies in 2024

Jones Day on

The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...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

Robinson+Cole Data Privacy + Security Insider

OCC Semiannual Risk Perspective Identifies AI as “Emerging Risk”

The Office of the Controller of the Currency (OCC) issues a semiannual risk perspective report that “addresses key issues facing banks, focusing on those that pose threats to the safety and soundness of banks and their...more

Ballard Spahr LLP

OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs

Ballard Spahr LLP on

In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating the overall soundness of...more

Cooley LLP

OCC Issues Risk Management Guidance for BNPL Lending

Cooley LLP on

On December 6, 2023, the Office of the Comptroller of the Currency (OCC) issued a bulletin that provides guidance to banks on managing risks associated with certain “buy now, pay later” (BNPL) loans. While the OCC notes that...more

Troutman Pepper

OCC’s Semiannual Report Highlights Emerging Risk of AI in Banking

Troutman Pepper on

On December 7, the Office of the Comptroller of the Currency (OCC) published the fall edition of its Semiannual Risk Perspective, which discusses key issues facing banks. From the OCC’s perspective, the overall strength of...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

Morrison & Foerster LLP

Federal Banking Agencies Adopt Climate-Related Financial Risks Guidance

On October 24, 2023, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (together, the “Agencies”) released their final Principles for Climate-Related...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

Troutman Pepper

OCC Updates Asset Management Booklet

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On June 22, the Office of the Comptroller of the Currency (OCC) released Version 1.0 of its Asset Management booklet, which provides an overview of sound risk management processes for bank asset management. The OCC will apply...more

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