Mick Grasmick

Mick Grasmick

Manatt, Phelps & Phillips, LLP

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Financial Services Law - July 2015

Treasury Department: Tell Us More About Online Marketplace Lending - Why it matters: Raising the possibility of regulation, the Department of the Treasury has published a Request for Information (RFI) regarding...more

7/30/2015 - CFPB Choke Point Consumer Lenders Decriminalization of Marijuana Depository Institutions Financial Institutions Online Marketplace Lending Payment Systems Peer-to-Peer Request For Information Small Business U.S. Treasury

Still Your Father’s Oldsmobile? Stale Bank Holding Company 10-K Sup & Reg Sections

It has been apparent for years that the common boilerplate Supervision and Regulation discussion in most bank holding company Form 10-K Annual Reports could be trimmed down and updated. Instead of rehashing longstanding...more

6/24/2015 - Annual Reports Bank Holding Company Form 10-K Regulation S-K Sanctions

Dodd-Frank Overkill—Community Bank M&A Deals Must Not Pose a Risk to U.S. Financial Stability

Why it matters - With their recent approvals of BB&T’s acquisition of a $2 billion community bank, the Federal Reserve Board of Governors (Federal Reserve) and the Federal Deposit Insurance Corporation (FDIC) were...more

6/24/2015 - Bank Merger Act Banking Sector Community Banks Dodd-Frank FDIC Federal Reserve Financial Institutions

The Next Examination Enforcement Wave— Cybersecurity Assessments?

Why it matters - The member banking agencies of the Office of the Federal Financial Institutions Examination Council (FFIEC) will soon promulgate a “Cybersecurity Assessment Tool” for use by community banks after a pilot...more

6/23/2015 - Anti-Money Laundering Bank Secrecy Act Banks Community Banks Cyber Attacks Cybersecurity Data Breach Data Protection FFIEC Financial Institutions

Virtual Currency Community Disappointed by Final BitLicense Regulation

Why it matters: The New York Department of Financial Services (DFS) released the final regulations for the much-anticipated BitLicense, the first state regulatory regime designed specifically for virtual/digital currency...more

6/22/2015 - Banks Bitcoins BitLicense Department of Financial Services Digital Currency Financial Institutions Software Software Developers Suspicious Activity Reports Virtual Currency

Comptroller Supports More CRA Credit for Small Business Lending while CRA Protests Continue to Stall M&A Deals

Why it matters - In recent remarks at the State Small Business Credit Initiative Conference, Comptroller of the Currency Thomas J. Curry discussed the state of small business credit programs, emphasizing the “crucial...more

6/11/2015 - CDFI Fund Community Banks Community Reinvestment Act FDIC OCC Small Business Small Business Jobs Act

Financial Services Weekly News Roundup - May 2015 #4

CFPB Fines Bank $7.5M for Overdraft Violations, With $49M More in Redress - Why it matters: In its first action targeting overdraft fees, the Consumer Financial Protection Bureau (CFPB) fined Regions Bank $7.5...more

5/29/2015 - Banks CFPB Choke Point Department of Financial Services FinCEN Overdraft Fees Preemption UK Virtual Currency Whistleblowers

We’re From the Government and We’re Here to Ease Your Regulatory Burden

Why it matters - The Office of the Comptroller of the Currency (OCC) is trying to make life easier for community banks, Comptroller Thomas J. Curry recently explained in a speech, working on legislation that would...more

4/24/2015 - Banks Community Banks FFIEC OCC Proposed Amendments

OCC Report Highlights Wide Range of Potential Risks

Why it matters - The OCC’s most recent report on current key risks should be read by all banks, regardless of size or regulator, as a road map in preparing for the next examination. Few banks would ever admit they may...more

1/20/2015 - Banking Sector Banks Corporate Governance Cybersecurity Industry Examinations OCC Popular Risk Assessment Risk Management Strategic Planning Underwriting

OCC Publishes Final Guidelines With Heightened Standards for Big Banks, Which All Banks Should Review

Risk management continues to be at the top of regulatory agendas, and the OCC has taken the opportunity to offer its heightened risk guidelines for large financial institutions of more than $50 million in average consolidated...more

9/26/2014 - Banks FDIC Foreign Banks OCC Risk Management

FDIC Clarifies Supervision of Bank/Third-Party Payment Processor Relationships

In an effort to rectify “misunderstandings” and get out of the line of political fire, the Federal Deposit Insurance Corporation (FDIC) issued updated guidance to clarify its supervisory approach to institutions establishing...more

8/14/2014

OCC Report Lists Key Risks For Review In Upcoming Examinations

Highlighting the operational, strategic, and compliance risks confronting financial institutions, the Office of the Comptroller of the Currency (OCC) published its “Semiannual Risk Perspective” report in late June based on...more

7/24/2014 - Banks FDIC OCC Risk Assessment

Comptroller Curry: Check The Shadows For Banking Threats

Where are the seeds of the next financial crisis? - Speaking at the Conference of State Bank Supervisors, Comptroller of the Currency Thomas Curry discussed threats to the national banking system and warned listeners...more

6/6/2014 - Banks Mortgage Servicers Mortgages Nonbank Firms Shadow Banking

Banking Law -- Aug 26, 2013

What Many Foreign Banks and Community Banks Have in Common - Strange as it may seem, community banks and the U.S. operations of foreign banks are often treated similarly; their interests are usually legislative and...more

8/27/2013 - Banks Community Banks Dodd-Frank Foreign Banks

Confidential Investigations of Bank Activities

Scenario: In the course of a safety and soundness examination, the bank examiners identify certain unusual transactions and bring the issue to the attention of management. Management, in turn, recognizing the potential...more

1/9/2013 - Audits Board of Directors Confidential Documents Disclosure Requirements Investigations

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