Jeffrey M. Werthan

Jeffrey M. Werthan

Katten Muchin Rosenman LLP

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OCC Issues Merchant Processing Booklet

On August 20, the Office of the Comptroller of the Currency (OCC) issued the “Merchant Processing” booklet of the Comptroller’s Handbook. This booklet, which replaces the booklet of the same name issued in December 2001, has...more

8/28/2014 - Anti-Money Laundering Bank Secrecy Act Banks Examiners Handbooks OCC

Corporate and Financial Weekly Digest - Volume IX, Issue 33

In this issue: - ISS Launches New Equity Plan Data Verification Portal - ISDA Publishes Protocol for 2014 Credit Derivatives Definitions - FinCEN Issues Advisories for US Financial Institutions -...more

8/25/2014 - CFTC Class Action Class Certification Compliance Contests & Promotions Derivatives EMIR Equity Plans ESMA EU FCA FinCEN Fraud ISDA ISS Judge Rakoff OCC Rule 10(b) SEC Security-Based Swaps SEFs Social Media Swap Dealers Swaps

OCC Issues Lease Financing Booklet of the Comptroller’s Handbook and Rescinds Earlier Publication

On August 12, the Office of the Comptroller of the Currency (OCC) issued the “Lease Financing” booklet of the Comptroller’s Handbook. This updated booklet replaces a similarly titled booklet issued in January 1998. The...more

8/21/2014 - Handbooks Leases OCC

OCC Increases Semiannual Assessment for Larger National Banks and Federal Savings Associations

On August 11, the Office of the Comptroller of the Currency (OCC) issued a final rule that increases the OCC’s semiannual assessment on national banks and federal savings associations (banks) with more than $40 billion in...more

8/20/2014 - Annual Assessments Banks Federal Savings Associations OCC

Corporate and Financial Weekly Digest - Volume IX, Issue 32

In this issue: - SEC’s Office of Investor Education and Advocacy Releases Alert on Identifying Fraudulent Private Placements - ICE Futures U.S. Issues Amendments to EFRP Rule and FAQs - Consumer Financial...more

8/18/2014 - AIFMD Banks Derivative Suit ESMA EU FCA Federal Savings Associations Fraud ICE OCC OCIE PSLRA SEC Securities Fraud Virtual Currency

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

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

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

OCC Issues “Asset-Based Lending” Booklet

On March 27, the Office of the Comptroller of the Currency (OCC) issued a new asset-based lending handbook. This booklet “expands the asset-based lending (ABL) examination fundamentals discussed in the ‘Accounts Receivable...more

4/9/2014 - Asset-Based Methodology Lending OCC

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

OCC and FDIC Issue Guidance on Deposit Advance Loans

On November 21, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) issued final supervisory “guidance” to supervised financial institutions that offer or may consider...more

11/27/2013 - Compliance Deposit Advances FDIC Loans OCC

OCC Publishes Standards on the Use of an Independent Consultant

On November 12, the Office of the Comptroller of the Currency (OCC) published standards governing the use of independent consultants in enforcement actions “involving significant violations of law, fraud, or harm to...more

11/20/2013 - Consultation Enforcement Actions OCC

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

Federal Reserve and OCC Issue Final Rules Replacing Existing Risk-Based and Leverage Capital Rules

The Office of the Comptroller of the Currency (OCC) and the Board of Governors of the Federal Reserve System published a final rule in the Federal Register on October 11 that replaces their existing risk-based and leverage...more

10/23/2013 - Basel III Capital Requirements Due Diligence FDIC Federal Reserve OCC

FFIEC Warns on Windows XP

On October 7, the Federal Financial Institutions Examination Council (FFIEC) issued a joint statement alerting financial institutions that the discontinuation of support (also known as “end of life”) for the Microsoft Windows...more

10/17/2013 - FFIEC Microsoft 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

OCC Revises Guidance on Commercial Real Estate Lending

On August 20, the Office of the Comptroller of the Currency (OCC) issued the “Commercial Real Estate Lending“ booklet of the Comptroller’s Handbook to replace the OCC’s “Commercial Real Estate and Construction Lending”...more

8/28/2013 - Commercial Real Estate Market Lending OCC

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

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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