Jonathan Levin

Jonathan Levin

Pepper Hamilton LLP

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Fear of Heights? OCC Adopts Heightened Standards for Risk Governance of Large Institutions

Wasting no time in leaving summer behind, on September 2, 2014, the Office of the Comptroller of the Currency (OCC) adopted Final Guidelines, to be published soon in the Federal Register, establishing risk governance...more

9/11/2014 - Banks FDIC Financial Regulatory Reform OCC Risk Assessment Risk Management

Sleeping Giant? OCC Wakes Up to New Focus on Merchant Processing

Following hard on the heels of recent risk management actions taken by other federal agencies, the Office of the Comptroller of the Currency (OCC) has issued a thoroughly updated booklet on Merchant Processing, which forms a...more

8/27/2014 - Anti-Money Laundering Bank Secrecy Act Banking Sector Banks OCC Payment Processors

Extended SEC MCDC Initiative Deadline Does Little to Lessen Urgency

The Securities and Exchange Commission (SEC) has recently modified its Enforcement Division’s Municipalities Continuing Disclosure Cooperation (MCDC) Initiative in order to encourage as much participation in the program as...more

8/19/2014 - Deadlines Enforcement Enforcement Actions MCDC SEC

Observation 1.0.1 on the Volcker Rule: With Summer Comes the First Wave — Of Guidance

A set of frequently asked questions, developed jointly and adopted in substantively identical form by the federal banking agencies (the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB) and the...more

7/3/2014 - Banking Sector CFTC FDIC Federal Reserve Guidance Update OCC SEC Volcker Rule

Mortgage Banking Takes Center Stage At OCC

On February 7, 2014, the Office of the Comptroller of the Currency (OCC) published a 232-page Mortgage Banking component to the Comptroller’s Handbook, its primary source of guidance for national banks and federal savings...more

2/25/2014 - Banks CFPB Mortgages OCC Qualified Mortgage Rule

Community Bank Alert: OCC Proposes Heightened Standards For Large Banks: How Big Is Large?

As explained in our January 24, 2014 Client Alert, “‘Heightened Standards’ for Large Banks: OCC Proposed Guidelines,” the Office of the Comptroller of the Currency (OCC) has released a proposal seeking comment on guidelines...more

1/28/2014 - Banks Larger Participant OCC Volcker Rule

‘Heightened Standards’ For Large Banks: OCC Proposed Guidelines

On January 16, 2014, the Office of the Comptroller of the Currency (OCC) released a proposal seeking comment on guidelines that would establish minimum standards of governance, risk management and board independence for...more

1/27/2014 - Banking Crisis Banking Examinations Banking Sector Financial Regulatory Reform OCC

Observation 1.1.1.1 On The Volcker Rule: Community Banks – Compliance Redux

In Observation 1.1.1, we discussed the surprise treatment under the new Volcker Rule regulations of collateral debt obligations (CDOs) backed by trust preferred securities (TruPS) as “covered funds,” which would force banking...more

1/20/2014 - Banking Sector Collateralized Debt Obligations Community Banks Final Rules Financial Regulatory Reform Market Making Regulatory Flexibility Act Trust Preferred Securities Volcker Rule

Observation 1.2 On The Volcker Rule: Foreign Banking Entities – Location, Location, Location

On December 10, 2013, the Board of Governors of the Federal Reserve System (FRB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), the Securities and Exchange Commission (SEC) and...more

1/17/2014 - Banks CFTC Collateralized Debt Obligations FDIC Federal Reserve Hedge Funds OCC Private Equity Proprietary Trading SEC Trust Preferred Securities Volcker Rule

Observation 1.1.1 On The Volcker Rule: Community Banks – Compliance

On December 10, 2013, the federal banking agencies jointly issued final regulations to implement the “Volcker Rule,” added to the Bank Holding Company Act by Section 619 of the Dodd-Frank Act, to prohibit banking entities and...more

1/10/2014 - Bank Holding Company Act Banking Sector Collateralized Debt Obligations Community Banks Dodd-Frank Financial Regulatory Reform Investment Fraud Proprietary Trading Regulatory Flexibility Act Securities Trust Preferred Securities Volcker Rule

Observation 1.1 On The Volcker Rule: Community Banks – Size Does Matter

On December 10, 2013, after more than three years of intensive development, the Board of Governors of the Federal Reserve System (FRB), Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation...more

12/24/2013 - Bank Holding Company Banks CFTC Dodd-Frank FDIC OCC SEC Volcker Rule

Observation 1.0 On The Volcker Rule

‘You Know It When You See It’ – Or Do You? - This is first in Pepper’s series of Client Alerts dealing with specific effects of the ‘Volcker Rule’ on various market segments. On December 10, 2013, after more than...more

12/17/2013 - Banking Sector Compliance Reporting Requirements Volcker Rule

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