Banking Examinations

News & Analysis as of

Tougher Scrutiny on Cybersecurity at Banks in 2016

Cybersecurity has been a focus as part of bank exams for years. Now the Federal Deposit Insurance Corp. (FDIC) is increasing its scrutiny of banks’ cybersecurity practices to ensure that the issue is getting appropriate...more

Federal Reserve Issues Guidance on Waiving of Examinations Prior to Membership or Merger Into a State Member Bank

On October 13, the Board of Governors of the Federal Reserve System (Board) issued guidance that applies to insured depository institutions that are seeking to become state chartered member banks of the Federal Reserve System...more

Corporate and Financial Weekly Digest - Volume X, Issue 42

SEC/CORPORATE - ISS Releases 2016 Draft Voting Policy Changes for Comment - On October 26, Institutional Shareholder Services (ISS), a leading proxy advisory firm, released for comment draft voting policy changes...more

Financial Regulatory Developments Focus - October 2015 #3

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

FinCEN Proposes AML Requirements for Registered Investment Advisers

The Financial Crimes Enforcement Network (FinCEN) has proposed long-expected regulations that would extend anti-money laundering (AML) requirements to federally registered investment advisers (RIA). The August 25, 2015...more

FDIC Hosts Teleconference on CFPB Mortgage Rules

On May 21, the FDIC’s Division of Depositor and Consumer Protection is scheduled to host a teleconference that will focus on the implementation of the new mortgage rules issued by the CFPB in 2013. According to the FDIC,...more

OCC Issues Updated RESPA Examination Guidance to Supervised Institutions

On April 14, the OCC issued the “Real Estate Settlement Procedures Act” booklet as part of the Comptroller’s Handbook, which is prepared for use by OCC examiners in connection with their examination and supervision of...more

The Financial Report (Global) - Volume 4, No. 1 • January 2015

News from the Americas - Non-bank SIFI designated. The US Financial Stability Oversight Council designated MetLife Inc. as a systemically important non-bank financial institution. (12/19/2014) Treasury Department press...more

FFIEC Releases Revised BSA/AML Examination Manual

The Federal Financial Institutions Examination Council (FFIEC) has released its revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. The revisions clarify supervisory expectations and incorporate...more

CFPB’s Ombudsman’s Office issues third annual report

Last week, the CFPB’s Ombudsman’s Office issued its third annual report covering the Office’s activities during fiscal year 2014 (October 1, 2013 through September 30, 2014). The role of the Ombudsman’s Office is to assist in...more

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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