News & Analysis as of

Climate Change Office of the Comptroller of the Currency

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2024

The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more

GeoDataVision

Climate Risk, the emerging risk

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This episode of the podcast, focusing on climate risk as an emerging regulatory compliance issue, features a dialogue between Len and Dean. They discuss how climate-related risks, especially in the financial sector, have...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 4, Issue 1, January 2024

OCC Issues Guidance on ‘Buy Now, Pay Later’ Lending - “The guidance notes that banks should maintain underwriting, repayment terms, pricing, and safeguards that minimize adverse customer outcomes and should ensure that...more

Jones Day

Final Climate Risk Guidance Ensures Supervisory Focus from Banking Agencies in 2024

Jones Day on

The Situation: In October 2023, the Office of the Comptroller of the Currency ("OCC"), Federal Reserve System, and Federal Deposit Insurance Corporation ("FDIC," and the three agencies collectively, "Agencies") finalized...more

ArentFox Schiff

New Federal Climate Change Guidance for Large Banks Outlines Risk Management Framework

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On October 24, US banking regulators, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (the “agencies”), issued long-awaited guidance...more

Latham & Watkins LLP

OCC, FRB, and FDIC Finalize Joint Principles for Climate-Related Financial Risk Management

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Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more

Holland & Knight LLP

Agency Guidelines Confirm That Climate-Related Financial Risk Is Real

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corp. (FDIC) (collectively, the Agencies) on...more

Snell & Wilmer

Climate-Related Financial Risk Management Final Interagency Guidance Rules Issued – Now What’s Next?

Snell & Wilmer on

On October 24, 2023, the Federal Reserve (Fed), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) issued the joint agency climate-related financial risk management guidance for...more

Orrick, Herrington & Sutcliffe LLP

Regulators release final principles for climate-related financial risk management

On October 25, the Fed, OCC, and FDIC issued final interagency guidance titled Principles for Climate-Related Financial Risk Management for Large Financial Institutions. The principles are intended to help the largest...more

Troutman Pepper

OCC Senior Deputy Comptroller for Large Bank Supervision Provides Insight on Impact to Community Banks of the OCC’s Principles for...

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On July 18, Office of the Comptroller of the Currency (OCC) Senior Deputy Comptroller for Large Bank Supervision Greg Coleman testified on OCC supervision of climate-related financial risks before the U.S. House of...more

Goodwin

Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial...

Goodwin on

Regulatory Developments - Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial Risks - On December 2, the Federal Reserve announced that it...more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2022

Headlines: ..OCC Publishes Security Standards for Video Teleconferencing With Agency Staff ..CFPB Imposes Civil Penalty and Customer Refunds for Authorized-Positive Overdraft Fees ..Treasury Department Recommends...more

Goodwin

OCC Solicits Research on Implications of Financial Technology for Banking

Goodwin on

Regulatory Developments - OCC Solicits Research on Implications of Financial Technology for Banking - On July 25, the OCC is seeking academic and policy-focused research on the impact that fintech and non-bank...more

Clark Hill PLC

The Current Expectations of the Financial Services Regulatory Agenda – And What To Do

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President Biden spent nearly 18 months assembling his team of top financial services regulators. Michael Barr’s nomination as the top banking regulator at the Federal Reserve Board (FRB) will fill the last remaining vacancy...more

White & Case LLP

Policy shifts may signal a new chapter in the story of globalization

White & Case LLP on

Globalization may be evolving, as nations and regions reassert their regulatory powers on a wide range of issues including trade, competition and national security. The economic lessons of COVID-19 and growing concerns about...more

Goodwin

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights, Issue 10

Welcome to our last Promissory Notes issue of 2021. As we all know, 2021 was another interesting year in the banking and finance industry, and we expect 2022 to be much the same. Our goal, as with all of our publications, is...more

White & Case LLP

Regulatory Hot Topics: Highlights

White & Case LLP on

It has been a period rife with notable shifts on the global stage; a new administration in the US, the end of the Brexit transition period and the reaching of key milestones in the discontinuation of LIBOR, to name but a few....more

Goodwin

CFPB Issues Interpretive Rule on FCRA Consumer Information Matching Requirements

Goodwin on

In This Issue. The Consumer Financial Protection Bureau (CFPB) issued an interpretive rule on Fair Credit Report Act consumer information matching requirements; the Securities and Exchange Commission (SEC) approved the Public...more

Holland & Knight LLP

Is the Sky Really Falling? Acting Comptroller Proposes Key Questions for Banks on Climate Change

Holland & Knight LLP on

Canadian singer-songwriter Joni Mitchell lamented the toil of deforestation in 1970: "They took all the trees, put 'em in a tree museum/And they charged the people a dollar and a half just to see 'em." More than 50 years...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Financial Regulators Signal That They Will Use Their Supervisory Authority To Press Climate Agenda

- Financial regulators will use their supervisory authority to make sure banks weigh the risks of lending to, investing in and otherwise supporting carbon centric activities. - The risk-based approach will force a...more

Goodwin

Treasury Department’s FSOC Acknowledges Climate Change as Threat to Financial Stability

Goodwin on

In This Issue. The Treasury Department’s Financial Stability Oversight Council (FSOC) issued a report acknowledging climate change as threat to financial stability; Federal Reserve Governor Michelle Bowman advocates for...more

Goodwin

SEC Publishes Sample Climate Change Comment Letter

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) published a sample comment letter on climate change disclosures; the Financial Industry Regulatory Authority (FINRA) is conducting a review of brokerage firm...more

Goodwin

Agencies Publish Notice and Request for Comment on Proposed Interagency Guidance on Third-Party Relationships

Goodwin on

In This Issue. The federal bank regulatory agencies requested public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships; the Office of the Comptroller of...more

Morrison & Foerster LLP

Financial Services Report - Summer 2021

As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more

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