Oliver I. Ireland

Oliver I. Ireland

Morrison & Foerster LLP

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OCC Announces Special Purpose National Bank Charter for FinTech Companies

On December 2, 2016, Comptroller of the Currency Thomas Curry confirmed that the agency will begin considering applications from FinTech companies to become special purpose national banks, saying that the OCC will charter...more

12/5/2016 - Applications Banking Sector FDIC FinTech OCC Public Comment

Financial Services Report, Fall 2016

Editor’s Note - So much for summer! The weather is cooling, the kids are back to school, and we better not see you wearing white so long after Labor Day! For those of you having a little trouble getting back in the...more

9/21/2016 - Anti-Money Laundering Arbitration CFPB Civil Monetary Penalty Debt Collection Digital Currency EU EU-US Privacy Shield Fair Lending FDIC FinCEN Foreclosure FTC Homeowner Bill of Rights Mortgage Lenders Municipalities OCC Online Banking SEC Standing Tax Revenues TCPA Telemarketing Volcker Rule

Federal Banking Agencies Issue Recommendations as Part of Their Section 620 Report to Solidify the Safety and Soundness of the...

On September 8, 2016, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Office of the Comptroller of the Currency (the “OCC,” and...more

9/12/2016 - Bank Holding Company Act Dodd-Frank FDIC Federal Bank Regulatory Agencies Federal Reserve Financial Holding Company Financial Sector Hedging OCC Prudential Standards Risk Management Savings and Loan Companies Volcker Rule

Penny Proof for Deposits: Federal Banking Regulators Issue Interagency Guidance Regarding Deposit Reconciliation Practices

On May 18, 2016, five federal banking agencies—the Board of Governors of the Federal Reserve System (“Board”), the Consumer Financial Protection Bureau (“CFPB”), the Federal Deposit Insurance Corporation (“FDIC”), the...more

5/23/2016 - Banking Regulators CFPB Deposit Accounts Expedited Funds Availability Act (EFAA) FDIC Federal Reserve Financial Institutions OCC

Is the End in Sight? FDIC Proposes the Net Stable Funding Ratio (“NSFR”): Liquidity Risk Measurement Standards and Disclosure...

On April 26, 2016, the Federal Deposit Insurance Corporation (the “FDIC”) proposed a rule (the “Proposed Rule”) that would implement a quantitative long-term liquidity requirement—the net stable funding ratio (“NSFR”)—for...more

4/28/2016 - Banking Regulators Banking Sector Derivatives Disclosure Requirements FDIC Liquidity Risk Management Rule Net Stable Funding Ratio (NSFR) Proposed Regulation

Financial Services Report, Spring 2016

Why another law firm newsletter? Over ten years ago, Will Stern answered that question in the first Editor’s Note of the first Financial Services Report. Some things have changed since then—we no longer print and mail paper...more

3/9/2016 - Arbitration CFPB Credit Cards Customer Lists Cybersecurity Debt Collection DOJ EU-US Privacy Shield Fair Lending FCRA FDIC Federal Reserve FTC HMDA Mortgages OCC Payday Loans Preemption SEC TCPA Truth in Lending Act (TILA)

Bubble, Bubble Toil and Trouble: The Fed Breathes Life into the Countercyclical Capital Buffer

Widespread problems in the banking system are often associated with sharp declines in asset prices, or the economy more broadly. When these declines result in loan defaults, bank capital can erode, leading to more stringent...more

12/24/2015 - Banks Basel III Dodd-Frank FDIC Federal Reserve

LCR – The Fed Takes Tentative Step to Expand HQLAs

When the Office of the Comptroller of the Currency (the “OCC”), the Board of Governors of the Federal Reserve System (the “Board”) and the Federal Deposit Insurance Corporation (the “FDIC”) finalized the Liquidity Coverage...more

6/2/2015 - Bank Holding Company Banks FDIC Federal Reserve Financial Institutions HQLA Liquidity Coverage Ratio Municipal Securities Issuers OCC

The Volcker Rule: Impact of the Final Rule on Foreign Banking Organizations

On December 10, 2013, the Federal Reserve, FDIC, OCC, SEC, and CFTC (the “Agencies”) issued the long-awaited final rule (“Final Rule”) construing the Volcker Rule. The Volcker Rule generally prohibits banking entities — a...more

12/12/2013 - CFTC Exemptions Extraterritoriality Rules FDIC Federal Reserve Foreign Banks OCC Proprietary Trading SEC Sovereign Debt Volcker Rule

High Quality Liquid Assets

This is not about top-shelf liquor, it is about today’s notice of proposed rulemaking…. At an open meeting today, the Federal Reserve Board (“FRB”) approved a proposed rule implementing a liquidity coverage ratio (“LCR”)...more

10/25/2013 - Banks Basel III FDIC Federal Reserve Liquidity Coverage Ratio OCC

They’re Here: The Final Interagency Regulatory Capital Rules

The Federal Reserve Board today approved the publication of the long-awaited final regulatory capital rules (“Final Rules” ), which were proposed one year ago (the “Proposed Rules”). While today’s action was taken by the...more

7/5/2013 - Bank Holding Company Basel Committee Basel III Capital Requirements FDIC Federal Reserve Leveraged Lending OCC Risk Management

Financial Services Report -- Winter 2012

In This Issue: Bureau Report; Operations Report; Beltway Report; Arbitration Report; Mortgage Report; Privacy Report; Preemption Report; and Plastics Report. Excerpt from the Bureau Report: World’s Most...more

12/18/2012 - American Express CFPB Chase Bank Cybersecurity Debt Collection Dodd-Frank FDIC FTC Google Mobile Apps MySpace Project Catalyst Stress Tests Truth in Lending Act (TILA)

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