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Due Diligence Office of the Comptroller of the Currency

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

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On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - January 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Nutter McClennen & Fish LLP

Nutter Bank Report: August 2023

A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more

McGlinchey Stafford

Interagency Guidance on Risks Associated with a Third-Party Relationship

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On June 6, 2023, the Board of the Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies) issued...more

Cozen O'Connor

Final Interagency Guidance on Managing Risks Associated with Third-Party Relationships

Cozen O'Connor on

On June 6, 2023, the Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency and Federal Deposit Insurance Corp. (collectively, the “Agencies”) issued final interagency guidance that...more

Pillsbury Winthrop Shaw Pittman LLP

Bank-Fintech Partnerships and Fair Lending: Top Areas at Risk for Government Scrutiny

The Federal Deposit Insurance Corporation (FDIC) recently published a consent order issued against Cross River Bank that alleged the bank’s fair lending program’s noncompliance and weaknesses in its oversight of fintech...more

Harris Beach PLLC

Recent Enforcement Actions Indicate Heightened Scrutiny of BSA/AML Compliance and Digital Assets

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Recent enforcement actions against banks indicate a new regulator emphasis on digital assets and Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance. Last year, Anchorage Digital Bank (Anchorage)—formerly Anchorage...more

Goodwin

Agencies Release Guide for Community Banks Conducting Due Diligence on Fintech Companies

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In August 2021, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Board of Governors of the Federal Reserve System (the Federal Reserve and, collectively with the...more

Perkins Coie

Fintech Legal Report - September 2021

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Federal Banking Agencies Issue Guide for Community Banks on Conducting Due Diligence on Fintech Companies - On August 27, 2021, the federal banking agencies (Federal Reserve, FDIC, and OCC) published “Conducting Due...more

Goodwin

CFPB Withdraws Proposal to Delay Debt Collection Final Rules

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In This Issue. The Consumer Financial Protection Bureau (CFPB) withdrew its proposal to delay the Debt Collection Final Rules; the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance...more

BCLP

Vetting FinTechs as Business Risk Partners: OCC Bulletin

BCLP on

Innovation is a key to competitive advantage and keeping pace with consumer digital banking preferences. Increasingly, banks are engaging the services of fintech’s who can deliver certain information and services in a more...more

Holland & Knight LLP

CFPB Proposes Settlement with Debt Collector for Failing to Investigate Identity Theft Reports

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With the ongoing COVID-19 pandemic, credit card companies may face increased scrutiny, as Consumer Financial Protection Bureau (CFPB) Acting Director Dave Uejio recently stated that "credit reports play a huge role in...more

Sheppard Mullin Richter & Hampton LLP

Federal Agencies Request Comments on Risk Management Guidance for Third-Party Relationships

On July 13, the Federal Reserve, FDIC, and OCC proposed risk management guidance to help banking organizations manage risks related to third-party relationships, including relationships with vendors, FinTech companies,...more

Perkins Coie

Fintech Week in Review - January 2021 #3

Perkins Coie on

Federal Regulation Actions Frozen Pending Review from New Administration - On January 20, 2021, newly inaugurated President Joe Biden issued a memorandum to the Heads of Executive Departments and Agencies asking current...more

Goodwin

OCC Proposes Rules for CRA Benchmarks and Fair Access

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more

Manatt, Phelps & Phillips, LLP

Third-Party Vendor Management Remains a Critical Issue for Banks

More than ever before, banks are relying on third-party vendors for important services such as marketing, underwriting assistance, technology, collections, settlement services and even outsourcing of product lines. These...more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

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In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

NAVEX

Banking Regulator Talks Third Party Risk, & All Should Listen

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Every compliance professional knows that managing third party risk can be a complex, difficult task. Now we have some fresh guidance from banking regulators on how to approach the subject — and regardless of your industry,...more

Goodwin

Financial Services Weekly News: FDIC Releases Guide To Connect Fintechs With Banks

Goodwin on

In This Issue. The Federal Deposit Insurance Corporation (FDIC) released a new guide to help financial technology companies and others partner with banks; the Financial Industry Regulatory Authority (FINRA) announced that it...more

Bradley Arant Boult Cummings LLP

Is the Bank Open? Federal Agencies Clarify Regulatory Requirements for Banking Hemp

On December 3, several federal agencies issued guidance (Guidance) that, by its terms, “provide[s] clarity” regarding “the regulatory requirements under the Bank Secrecy Act (BSA) for banks providing services to hemp-related...more

Goodwin

Financial Services Weekly Roundup - June 2018 #2

Goodwin on

Editor's Note - In This Issue. The Securities and Exchange Commission (SEC) issued a no-action letter that closes the gap in investor protection created by the SEC’s approval of FINRA Rule 2165; the SEC’s Investment...more

Vedder Price

How to Evaluate Cyber Insurance Options?

Vedder Price on

On April 10, 2018, the Federal Financial Institutions Examination Council (the “FFIEC”), an interagency body composed of the Board of Governors of the Federal Reserve System, Consumer Financial Protection Bureau, Federal...more

Goodwin

Financial Services Weekly News - November 2017 #2

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Editor's Note - Change at the Fed. As expected, on November 2, President Trump nominated Jerome H. Powell to be Chairman of the Board of Governors of the Federal Reserve System (FRB) for a term of four years beginning...more

Ballard Spahr LLP

OCC issues risk management principles for new activities

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On October 20, 2017, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2017-43 (the “Bulletin”) outlining principles that OCC-supervised banks should follow to prudently manage the risks associated with...more

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