Jeffrey Werthan

Jeffrey Werthan

Katten Muchin Rosenman LLP

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Federal Bank Regulatory Agencies Release CRA Asset-Size Thresholds for Small and Intermediate Small Institutions

On December 22, 2015, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation and Office of the Comptroller of the Currency (collectively, Agencies) announced the annual adjustment to the...more

1/14/2016 - Banks CRA Federal Reserve Federal Savings Associations Threshold Requirements

Federal Banking Agencies Seek Comment on Interagency Effort To Reduce Regulatory Burden

On December 17, the Federal Financial Institutions Examination Council, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation and Board of Governors of the Federal Reserve (collectively, federal...more

12/23/2015 - Banks Comment Period EGRPRA Regulatory Agencies

OCC Issues Recovery Proposal for Institutions With Assets of $50 Billion or More

On December 17, the Office of the Comptroller of the Currency (OCC) requested comment on a proposed rule to establish enforceable guidelines for recovery planning by insured national banks, insured federal savings...more

12/23/2015 - Banks Foreign Branches of U.S. Banks OCC Proposed Regulation Recovery Plans

OCC Announces Calendar Year 2016 Fees and Assessments Structure

On December 1, the Office of the Comptroller of the Currency (OCC) announced in Bulletin 2015 – 47 the fees and assessments that will be charged by the OCC for calendar year 2016. The bulletin becomes effective January 1,...more

12/9/2015 - Assessment Banking Sector Banks Fees OCC

FDIC Board Votes To Increase DIF to 1.35 Percent of Insured Deposits

On October 22, The board of directors of the Federal Deposit Insurance Corporation (FDIC) adopted a proposal to increase the Deposit Insurance Fund (DIF) to the statutorily required minimum level of 1.35 percent. Congress,...more

10/28/2015 - Banks Deposit Insurance Dodd-Frank FDIC Proposed Regulation

Corporate and Financial Weekly Digest - Volume X, Issue 41

SEC/CORPORATE - SEC To Hold Forum on Small Business Capital Formation in November - On October 21, the Securities and Exchange Commission announced that it will hold its annual Government - Business Forum on Small...more

10/26/2015 - AML-CTF Banks Capital Formation Deposit Insurance EU European Banking Authority European Securities and Markets Authority (ESMA) FDIC JOBS Act Margin Requirements Regulation Technical Standards (RTS) SEC Small Business Startups Uncleared Swaps

OCC Announces Update to Accounting Interpretations On TDRs, OREO and Pushdown Accounting

On September 29, the Office of the Comptroller of the Currency (OCC) released an update to the Bank Accounting Advisory Series (BAAS). The BAAS covers a variety of topics and promotes consistent application of accounting...more

10/8/2015 - Accounting Standards Banking Sector Banks GAAP OCC

Federal Reserve To Require Same-Day ACH Service

On September 23, the Federal Reserve Board announced the approval of “enhancements” to the Federal Reserve Banks’ same-day automated clearing house (ACH) service. According to the Fed, “[t]he enhancements are intended to...more

10/1/2015 - ACH Payments Automated Clearing House (ACH) Banks Federal Reserve Financial Institutions NACHA

Federal Reserve Issues Final Rule Requiring GSIBs to Bolster Capital

The Federal Reserve Board on July 20 approved a final rule requiring the largest, most systemically important US bank holding companies to further strengthen their capital positions. Under the rule, a firm that is identified...more

7/30/2015 - Bank Holding Company Banks Capital Requirements Federal Reserve Final Rules G-SIB

OCC Revises Guidance and Forms for Subordinated Debt Issued for Tier 2 Capital and Non-Capital Purposes

The Office of the Comptroller of the Currency (OCC) is revising and reorganizing its current guidance for subordinated debt issued by national banks (at appendix A of the “Subordinated Debt” booklet of the Comptroller’s...more

4/22/2015 - Banking Sector Banks Capital Rules Guidance Update OCC Regulatory Standards Subordinated Debt

Federal Reserve Board Expands Small Bank Holding Company Policy Statement

On April 9, the Board of Governors of the Federal Reserve (Board) issued a final rule to expand the applicability of its Small Bank Holding Company Policy Statement and also apply it to certain savings and loan holding...more

4/22/2015 - Bank Holding Company Banking Sector Banks Federal Reserve Final Rules

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

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

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 Threshold 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

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

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 Bitcoin 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 Truth in Lending Act (TILA)

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