Banking Examinations

News & Analysis as of

OCC steps up SCRA focus in exams

As we have been reporting, the CFPB has made the Servicemembers Civil Relief Act (SCRA) a major focus and instructs its examiners to look at SCRA compliance during examinations. The OCC has also stepped up its focus on SCRA...more

‘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

Second Annual CFPB Ombudsman Report Recommends Exam Changes

On December 3, the CFPB Ombudsman’s Office submitted its second annual report to the Director of the CFPB. The report contains an update on the systemic recommendations made last year and new recommendations stemming from the...more

CFPB To Stop Sending Enforcement Attorneys To Exams

The CFPB has decided to end its policy of sending enforcement attorneys to routine examinations of supervised financial institutions. The policy change will take effect on November 1, 2013....more

Compelled Waiver of Foreign Bank Secrecy for Discovery of Records Abroad

There are many branches, agencies, and subsidiaries of foreign banks licensed to conduct banking business here in New York. These foreign-bank offices are often the targets of civil discovery requests seeking production of...more

Federal District Court Denies OCC’s Motion Seeking Reconsideration Of Order Compelling Production Of Materials Subject To Bank...

On May 23, the U.S. District Court for the Southern District of New York denied the OCC’s motion for reconsideration of an April 2013 order in which the court compelled a bank and the OCC to produce various investigative...more

Policy, Procedures, and Examinations - Mortgage Brokers

In this article, the first of a two-part series, I am going to provide a chart of certain core policies and procedures that a mortgage broker should obtain and continually update, as regulations change. I will also provide...more

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