Jeffrey M. Werthan

Jeffrey M. Werthan

Katten Muchin Rosenman LLP

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FDIC Proposes Changes to Assessments Rule

On July 15, the Federal Deposit Insurance Corporation (FDIC) proposed (1) to revise the ratios and ratio thresholds for capital evaluations used in its risk-based deposit insurance assessment system (the FDIC stated this was...more

7/24/2014 - Banks Basel III Capital Requirements FDIC Federal Reserve Leverage Capital Ratio OCC

FFIEC Member Agencies and State of New York to Focus Attention on Cybersecurity

On May 7, the Federal Financial Institutions Examination Council (FFIEC) highlighted regulatory efforts to enhance financial institutions’ cybersecurity during a webinar for approximately 5,000 chief executive officers and...more

5/15/2014 - Banks Cybersecurity FFIEC Financial Companies Nonbank Firms Risk Assessment Risk Management

FDIC Releases Resource Guide to Help Institutions Evaluate Opportunities with Community Development Financial Institutions

The Federal Deposit Insurance Corporation (FDIC) has produced a resource guide, Strategies for Community Banks to Develop Partnerships with Community Development Financial Institutions, to inform institutions of strategies to...more

5/14/2014 - Banks CDFI Fund CRA FDIC Public-Private Partnerships

Banking Agencies Adopt Enhanced Supplementary Leverage Ratio Final Rule

On April 8, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) adopted a final rule to strengthen the leverage ratio...more

4/17/2014 - Banks FDIC Federal Reserve Leverage Ratio OCC

Federal Reserve Extends Compliance Deadline for CLOs

On April 7, the Federal Reserve Board (Board) announced that it intends to exercise its authority to give banking entities two additional one-year extensions to conform their ownership interests in, and sponsorship of,...more

4/17/2014 - Banks Collateralized Loan Obligations Federal Reserve Time Extensions Volcker Rule

OCC Issues Garnishment Guidance

On April 1, the Office of the Comptroller of the Currency (OCC) issued the “Garnishment of Accounts Containing Federal Benefit Payments” booklet, which is new to the Comptroller’s Handbook. The booklet contains interagency...more

4/10/2014 - Banks Compliance Garnishment OCC Wage Garnishment

Agencies Issue Denial of Service Guidance and Guidance on ATMs

On April 3, the members of the Federal Financial Institutions Examination Council (FFIEC), including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union...more

4/10/2014 - ATMs Banks Cyber Attacks Data Breach Data Protection Encryption Heartbleed

Federal Reserve Approves Final Rule Regulating Bank Holding Companies and Foreign Banking Organizations

On February 18, the Federal Reserve Board (Federal Reserve) approved a Final Rule to enhance supervision over the largest US bank holding companies (BHCs) and the largest foreign banking organizations (FBOs) with operations...more

2/26/2014 - Bank Holding Company Banks Dodd-Frank Federal Reserve Foreign Banks

OCC Proposes Risk Guidelines for Large Banks; Plans to Apply Part 30 to Federal Savings Institutions

On January 16, the Office of the Comptroller of the Currency (OCC) released a proposal setting forth new standards based on the agency’s heightened expectations program for large national banks and federal savings...more

1/23/2014 - Banks Compliance FDIA Federal Savings Associations OCC

Corporate and Financial Weekly Digest - Volume IX, Issue 3

In this issue: - CFTC Issues No-Action Relief to FCMs Relating to Enhanced Customer Protection Rules - Eleventh Circuit Upholds Directors’ Affirmative Defenses Based on FDIC’s Post-Receivership Conduct -...more

1/20/2014 - Affirmative Defenses Banks CFTC Collateralized Debt Obligations Directors FCMs FDIC Insider Trading No-Action Relief OCC Professional Liability Receivership Scienter Trust Preferred Securities

Agencies Appear to Signal Retreat on CDO TruPS Issue

In the wake of the American Bankers Association’s lawsuit challenging the Volcker Rule’s treatment of collateralized debt obligations (CDOs) backed by trust preferred securities (TruPS), the Office of the Comptroller of the...more

1/9/2014 - American Bankers Association Banks Collateralized Debt Obligations Proprietary Trading Trust Preferred Securities Volcker Rule

Five Agencies Issue Final Volcker Implementation Rules; Small Banks Win Exemptions

On December 10, five financial regulatory agencies (the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Securities and Exchange Commission...more

12/17/2013 - Banks CEOs Compliance Proprietary Trading Volcker Rule

Agencies Release Final Revisions to Interagency Q&As Regarding Community Reinvestment

On November 15, the federal bank regulatory agencies with responsibility for Community Reinvestment Act (CRA) rulemaking published final revisions to Interagency Questions and Answers Regarding Community Reinvestment. The...more

11/20/2013 - Banks CRA

OCC Issues Risk Management Guidance

On October 30, the Office of the Comptroller of the Currency (OCC) issued guidance (Bulletin 2013-29) to national banks and federal savings associations (collectively, banks) for assessing and managing risks associated with...more

11/7/2013 - Banks Compliance OCC Risk Management

OCC and FDIC Propose Rule to Strengthen Liquidity Risk Management

On October 30, as expected, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) each proposed a rule to strengthen the liquidity risk management of large banks and savings...more

11/7/2013 - Banks FDIC Federal Reserve Liquidity Coverage Ratio OCC

Federal Reserve Issues Proposed Liquidity Requirements; OCC and FDIC Expected to Follow

On October 24, the Board of Governors of the Federal Reserve System, in an expected move, issued tough new liquidity requirements generally applicable to banks with assets over $250 billion and somewhat diluted liquidity...more

11/4/2013 - Banks FDIC Federal Reserve Liquidity Coverage Ratio OCC

OCC Updates Bank Accounting Advisory Series

On October 10, the Office of the Comptroller of the Currency (OCC) released an update to the Bank Accounting Advisory Series (BAAS)....more

10/17/2013 - Banks OCC

FDIC Issues Final Rule Clarifying That Deposits in Foreign Branches of US Banks Are Not Insured

On September 12, the Board of Directors of the Federal Deposit Insurance Corporation (FDIC) approved a final rule clarifying that deposits in foreign branches of US banks are not FDIC-insured, even though they can be deposits...more

9/18/2013 - Banks FDIC Federal Deposit Insurance Act Final Rules Foreign Banks Foreign Branches of U.S. Banks Insureds Insurers

Agencies Seek to Bolster Leverage Ratio Standards for Largest Banks

On August 20, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), and the Federal Deposit Insurance Corporation (FDIC) (collectively, the Agencies) announced that...more

8/28/2013 - Banks FDIC Federal Reserve OCC Proposed Regulation

Agencies Seek Comment on Dodd-Frank Act Stress Test Guidance for “Medium-sized” Banking Firms

On July 30, three federal bank regulatory agencies, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (Agencies), sought comment...more

8/7/2013 - Banks Dodd-Frank FDIC Federal Reserve OCC Stress Tests

Federal Reserve, OCC and FDIC Propose Higher Capital Requirements for Largest Banks

On July 9, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (collectively, the Agencies) issued a joint notice of proposed...more

7/18/2013 - Banks Capital Requirements Compliance FDIC Federal Reserve OCC Proposed Regulation

Banking Agencies Issue Final Basel III Capital Regulations

A new regulatory capital framework for US banks has been introduced by the issuance on July 2 of final capital regulations (the Final Regulation) for bank holding companies and state-chartered member banks by the Board of...more

7/18/2013 - Banks Basel Committee Basel III Dodd-Frank FDIC New Regulations OCC

Federal Reserve Proposes to Collect Additional Data Every Day on Fed Funds, Eurodollars and CDs from Larger Banks

The Federal Reserve proposes to implement the mandatory Report of Selected Money Market Rates (FR 2420)....more

7/4/2013 - Banks CDS EU Federal Reserve Foreign Banks Money Market Funds

Federal Reserve to Vote on Final Capital Rules

On June 27 the Board of Governors of the Federal Reserve System (Federal Reserve) announced that it will vote this Tuesday on the final version of rules that will require financial institutions to achieve higher levels of...more

7/4/2013 - Banks Capital Rules Federal Reserve

OCC Adjusts Policy Statement to Facilitate Capital Raising by Minority Institutions

On June 11, Comptroller of the Currency Thomas J. Curry told an interagency conference on minority depository institutions (MDI) and community development financial institutions that the Office of the Comptroller of the...more

6/19/2013 - Banks Capital Requirements Community Development Entities Equity Financing MDI OCC

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