Jeffrey Werthan

Jeffrey Werthan

Katten Muchin Rosenman LLP

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FDIC Issues Private Letter to Elaborate on Brokered Deposit FAQ

On February 4, representatives of the Federal Deposit Insurance Corporation (FDIC) sent a letter to David Hanrahan, the president and CEO of Capital Bank of New Jersey, in which they elaborated on a particular question and...more

2/19/2015 - Banks Brokered Deposits FDIC Private Letter Rulings

OCC Releases Bulletin Summarizing Interim Final Rule on Subordinated Debt Issued by National Banks

On February 6, the Office of the Comptroller of the Currency (OCC) issued OCC Bulletin 2015-11, which describes further clarifications to an interim final rule on subordinated debt that was issued on February 28, 2014. The...more

2/19/2015 - Banking Sector Banks OCC Subordination

OCC Issues Revised Comptroller’s Handbook Booklet on Deposit-Related Consumer Credit

On February 11, the Office of the Comptroller of the Currency (OCC) issued the “Deposit-Related Consumer Credit” booklet of the Comptroller’s Handbook. This booklet replaces the “Check Credit” booklet issued in March 1990,...more

2/19/2015 - Banking Sector Consumer Financial Products Deposit-Related Consumer Credit Guidance Update OCC

Agencies Issue Tool for Calculating Capital Requirements for Securitization Exposures

On February 11, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation issued an automated tool to help national banks and...more

2/19/2015 - Banking Sector Banks Capital Requirements Federal Reserve Securitization Market Securitization Vehicles

Corporate and Financial Weekly Digest - Volume X, Issue 6

In this issue: - SEC Publishes Rules for Reporting Security-Based Swaps - SEC Proposes Rules for Disclosure of Companies’ Hedging Policies - CFTC Extends Relief From Certain OCR Requirements - NFA...more

2/17/2015 - Arbitration Banking Sector Banks Bribery Brokered Deposits Capital Requirements CFTC Clawbacks FDIC Haiti Hedging NFA OCC SEC Security-Based Swaps Subordination

Federal Reserve Board Invites Comments on Small Bank Holding Company Policy Statement

On January 29, the Board of Governors of the Federal Reserve System (Board) invited public comment on a proposed rule to expand the applicability of the Board’s Small Bank Holding Company Policy Statement (Policy Statement)...more

2/13/2015 - Bank Holding Company Banking Sector Banks Community Banks Federal Reserve

Regulators Release Guidance on Private Student Loans With Graduated Repayment Terms at Origination

On January 29, the federal financial regulatory agencies, in partnership with the State Liaison Committee of the Federal Financial Institutions Examination Council, issued guidance for financial institutions on private...more

2/12/2015 - CFPB Consumer Lenders ECOA EFTA FDIC New Guidance Private Student Loans Student Loans TILA

Corporate and Financial Weekly Digest - Volume X, Issue 5

In this issue: - SEC Advisory Committee on Small and Emerging Companies to Discuss “Accredited Investor” Definition - Glass Lewis Enhances its Pay-for-Performance and Equity Plan Models - SEC Issues New...more

2/9/2015 - Accredited Investors CBOE Cybersecurity Emerging Growth Companies Enforcement Actions Equity Plans ESMA Exchange Offer Federal Reserve FINRA Glass Lewis Pay-for-Performance Ponzi Scheme Private Student Loans Proposed Amendments SEC Small Business Tender Offers

CFPB Finalizes Minor Changes to “Know Before You Owe” Mortgage Rules

On January 20, the Consumer Financial Protection Bureau (CFPB) finalized two minor modifications to the “Know Before You Owe” mortgage disclosure rules. The changes, which were proposed in October 2014, address when consumers...more

1/29/2015 - CFPB Disclosure Requirements Mortgages TILA

OCC Issues New Comptroller’s Handbook Sections Relating to Securities Compliance, Litigation and Conflicts of Interest

On January 22, the Office of the Comptroller of the Currency (OCC) issued the “Government Securities Act” booklet of the Comptroller’s Handbook. This new booklet, part of the Securities Compliance series, consolidates certain...more

1/28/2015 - Conflicts of Interest Handbooks OCC Regulatory Standards Securities Securities Litigation

Corporate and Financial Weekly Digest - Volume X, Issue 3

In this issue: - SEC Chair Directs Staff to Review Commission Rule Excluding Conflicting Proxy Proposals - SEC Comments on FINRA's Proposed Rule Amendment to Increase Pricing Disclosure - CFTC Grants...more

1/26/2015 - Broker-Dealer Canada CFTC Class Action Conflicts of Interest ESMA FINRA Forex Hart-Scott-Rodino Act Hong Kong Layering Mary Jo White Mexico Mining Mortgages NFA OCC Proposed Regulation Proxy Access Rule PSLRA Scienter SEC Securities Shareholder Proposals Threshhold Requirements Whole Foods

Agencies Release Annual CRA Asset-Size Threshold Adjustments for Small and Intermediate

On December 19, 2014, the federal bank regulatory agencies announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank and intermediate small...more

1/16/2015 - Banking Sector Banks CRA FDIC Threshhold Requirements

FDIC Releases Guidance on Brokered Deposits in the Form of FAQs

On January 5, in its second Financial Institution Letter of 2015, the Federal Deposit Insurance Corporation (FDIC) released guidance in the form of frequently asked questions (FAQs) with respect to identifying, accepting and...more

1/16/2015 - Banking Sector Banks Brokered Deposits FDIC New Guidance

Corporate and Financial Weekly Digest - Volume X, Issue 1

In this issue: - SEC Proposes Rule Amendments to Implement JOBS Act Registration Thresholds - ISS Releases FAQs on Equity Plan Scorecard and Independent Chair Policy - FINRA Issues Annual Regulatory and...more

1/12/2015 - CFTC CME Equity Plans FCMs FINRA Independent Boards ISS JOBS Act NASD No-Action Relief REITS SEC Strategic Enforcement Plan

Congress Eases Debt Level Restrictions for Smaller Banks, Thrifts

On December 11, Congress passed legislation redefining the size of smaller institutions allowed to take advantage of the Federal Reserve’s Small Bank Holding Company Policy Statement from less than $500 million to less than...more

12/31/2014 - Bank Holding Company Banks Federal Reserve New Legislation

OCC Issues Bank Accounting Advisory Series Update

On December 12, the Office of the Comptroller of the Currency issued an updated version, dated October 2004, of its Bank Accounting Advisory Series (BAAS). ...more

12/30/2014 - Accounting Banks OCC

FFIEC Releases Revised BSA/AML Examination Manual

On November 26, the Federal Financial Institutions Examination Council (FFIEC) released the revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. ...more

12/12/2014 - Annunzio-Wylie Anti-Money Laundering Act Bank Secrecy Act FDIC Federal Reserve FFIEC Financial Institutions FinCEN Nonbank Firms OFAC

OCC’s Curry Advocates Regulatory Reduction for Smaller Banks and Thrifts

Speaking on December 2 at an Interagency Outreach Meeting on the Economic Growth and Regulatory Reduction Act (EGRPRA), Comptroller of the Currency Thomas J. Curry indicated his desire to roll back regulatory burdens on...more

12/11/2014 - Banks OCC Regulatory Agenda

Corporate and Financial Weekly Digest - Volume IX, Issue 47

In this issue: - SEC Sets October 2015 Target Date for Certain Dodd-Frank and JOBS Act Rulemaking - FINRA Issues Notice on TRACE Trade Reporting Obligations - NFA Issues Guidance on Exempt and Excluded...more

12/8/2014 - AIFM Bank Secrecy Act Banks Bitcoins BitLicense C-Suite Executives CPOs CTA Dodd-Frank Enforcement Actions EU EU Data Protection Laws False Statements FFIEC FINRA Investment Funds JOBS Act NFA OCC Proposed Amendments Regulatory Standards Rulemaking Process SEC TRACE Whistleblower Awards

CFPB Issues Broader Than Expected Prepaid Card Proposal and Model Forms

On November 13, the Consumer Financial Protection Bureau (CFPB) issued its long-awaited proposal with respect to prepaid cards. This proposal, which consisted of 870 pages, covers traditional prepaid cards as well as mobile...more

11/19/2014 - Banks CFPB Financial Institutions Prepaid Payment Products Proposed Regulation Rulemaking Process TILA

Corporate and Financial Weekly Digest - Volume IX, Issue 45

In this issue: - Proxy Advisory Firms Release Policy Updates for 2015 - CBOE Makes Enhancements to Its Market-Maker Trade Notification System - OTC Derivatives Regulators Group Issues Report to G20...more

11/17/2014 - AIFM AIFMD CBOE CFTC Derivatives ESMA Financial Conduct Authority G20 Glass Lewis ISS Market Making OTC Prepaid Payment Products Proxy Season Proxy Voting Guidelines

OCC Revises Process for Managing Matters Requiring Attention

The Office of the Comptroller of the Currency (OCC) on October 30 published revised policy and procedures for how it manages Matters Requiring Attention (MRAs) resulting from its examination of supervised institutions. MRAs...more

11/5/2014 - Banks Corporate Executive Boards Corporate Management OCC Policies and Procedures Supervision

Agencies Request Comment on Proposed Flood Insurance Rule

Five federal regulatory agencies on October 24 announced the approval of a joint notice of proposed rulemaking to amend regulations pertaining to loans secured by property located in special flood hazard areas. The proposed...more

11/5/2014 - Biggert-Waters Flood Insurance Reform Act Farm Credit Administration FDIC Federal Reserve Flood Insurance Flood Zones HFIAA NCUA OCC Proposed Amendments Rulemaking Process

Six Federal Agencies Jointly Approve Final Risk Retention Rule

Six federal agencies approved on October 22 a final rule requiring sponsors of securitization transactions to retain risk in those transactions. The final rule implements the risk retention requirements in the Dodd-Frank Wall...more

11/5/2014 - ABS Asset-Backed Securities Dodd-Frank FDIC Federal Reserve FHFA Final Rules HUD Mortgage-Backed Securities OCC Qualified Mortgage Rule Risk Retention SEC

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