Jeffrey Werthan

Jeffrey Werthan

Katten Muchin Rosenman LLP

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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

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

Corporate and Financial Weekly Digest - Volume IX, Issue 43

In this issue: - ISS Announces Launch of QuickScore 3.0 - SEC Provides Relief to GSEC From Rule 204 Close-Out Requirements - CFTC Extends Relief to FCMs from Certain Commingling Requirements -...more

11/3/2014 - Banks CCPs CFTC Class Action Commingling Commodities Compliance EMIR ESMA EU European Commission FCMs Fixed Income Investments Flood Insurance Foreign Banks Foreign Exchanges ISS OCC Risk Retention SEC Securities Litigation UK

Banking Agencies Request Comment on Proposed Questions and Answers Regarding Community Reinvestment

On September 8, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency requested comment on proposed revisions to the “Interagency...more

9/18/2014 - Banks Community Reinvestment Act FDIC Federal Reserve OCC Proposed Amendments

Federal Banking Regulators Finalize Liquidity Coverage Ratio

On September 3, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency finalized a rule to strengthen the liquidity positions of large financial institutions.The...more

9/10/2014 - Banks Basel Committee Dodd-Frank FDIC Federal Reserve Final Rules HQLA Liquidity Coverage Ratio OCC

Banking Agencies Adopt Supplementary Leverage Ratio Final Rule

On September 3, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency adopted a final rule modifying the definition of the denominator of the supplementary...more

9/10/2014 - Banks Basel Committee Basel III FDIC Federal Reserve Leverage Ratio OCC

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

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