News & Analysis as of

What’s Unfair is Unfair: Repeal of Reg AA May Have Little Practical Effect

The Federal Reserve Board (Board) issued a notice of proposed rulemaking on August 22, 2014 (Notice) for the repeal of Regulation AA, which is the Board’s credit practices rule prohibiting certain unfair or deceptive acts and...more

Do Guarantors Fall under the Protection of the Equal Credit Opportunity Act?

We have discussed the Equal Credit Opportunity Act (“ECOA”), which makes it unlawful for a creditor to discriminate against an applicant in any aspect of a credit transaction on the basis of, among other things, the...more

Despite FAQs and OCC Interim Examination Procedures, Little Illumination So Far for Volcker Rule Compliance

June 2014 saw the publication of some interagency FAQs on the Volcker Rule (the Rule) and interim procedures from the Office of the Comptroller of the Currency (OCC) for its examiners to use in assessing progress by national...more

New York Federal Reserve Bank Official Questions FCPA’s “Facilitating Payments” Exception

On July 23, Thomas Baxter, General Counsel for the New York Federal Reserve Bank, in public remarks at a risk management conference, questioned the FCPA’s “exception for ‘facilitating or expediting payments’ made in...more

SEC and Banking Agencies Release Volcker Rule FAQs; OCC Issues Interim Volcker Rule Examination Procedures

The SEC, FRB, OCC and FDIC (collectively, the “Agencies”) recently issued FAQs regarding implementation of Section 13 of the Bank Holding Company Act (the “Volcker Rule”). (The FAQs issued by each of the Agencies are...more

Federal Banking Agencies Seek Comments on Their Regulations in Effort to Reduce Regulatory Burden

The FRB, FDIC and OCC (the “Agencies”) published the first of a series of four requests seeking public comments to identify regulations of the respective Agencies that are seen as outdated, unnecessary or unduly burdensome. ...more

Federal Reserve Board Proposes Liability Concentration Limit

On May 8, the Federal Reserve Board released a proposed rule that would prohibit certain financial companies from combining with another company if the resulting financial company’s liabilities would exceed 10% of the...more

The Financial Report - Volume 3, No. 10 • May 2014 (Global)

News from the Americas - High-speed trading. Bloomberg discussed US Senate Agriculture Committee hearings on high-speed trading. Former CFTC economist Andrei Kirilenko said that new books and records requirements and...more

Banking Agencies Issue Proposed Rules for Appraisal Management Companies, as Required under Dodd-Frank

On Wednesday, April 9, 2014, the Office of the Comptroller of the Currency, the Federal Reserve System, the Federal Deposit Insurance Corporation, the Consumer Financial Protection Bureau and the Federal Housing Finance...more

Banking balkanisation?

In mid-February 2014, the Federal Reserve approved the final enhanced prudential rule for foreign banking organisations (FBOs) under Section 165 of the Dodd-Frank Act. The final rule applies enhanced standards to FBOs that...more

State Banking Associations Object To Senators’ Request For Increased Bank Payment System Security Oversight

On March 5, 53 state bankers associations sent a letter to Federal Reserve Board Chair Janet Yellen defending banks’ efforts to secure consumer financial data and highlighting the responsibilities of other parties, in...more

Federal Reserve Board Seeks Comment On Designated Utilities’ Risk Management Standards, Payment System Risk Policy

On January 10, the Federal Reserve Board proposed revisions to the Regulation HH risk-management standards for certain financial market utilities that have been designated as systemically important by the Financial Stability...more

Legal Alert: Final Volcker Rule: Update and Key Takeaways

On December 10, 2013, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Securities and Exchange Commission and the Commodity Futures...more

Prudential Regulators Announce Coordinated Action Against Technology Service Provider

Recently, the OCC released a formal agreement it entered with the FDIC, the Federal Reserve Bank of St. Louis, and a banking software company to resolve allegations of unsafe and unsound practices relating to the software...more

A Review of, and Insights into, the Volcker Rule Regulations

Executive Summary: ..The final regulations (Regulations) adopted by the five federal financial regulatory agencies (Agencies) on December 10, 2013 to implement the proprietary trading and private fund prohibitions of...more

The Volcker Rule: Great Expectations For Regulating Risk

On Tuesday, December 10, five federal regulatory agencies, the Federal Reserve, the Securities and Exchange Commission, the Federal Deposit Insurance Corporation, the Office of the Comptroller and the Commodity Futures...more

Key Provisions of the Volcker Rule Final Regulations for Non-US Banking Entities

The five US financial agencies (“Agencies”) have approved jointly prepared final regulations (“Final Rules”) to implement the prohibitions on engaging in proprietary trading and investment in or sponsorship of a private...more

Summary of the Volcker Rule

On December 10, 2013, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the Securities and Exchange Commission, and the Commodity...more

Ready for the Volcker Rule? What to Look For

Over two years after publication of a proposed regulation, a final regulation implementing the so-called “Volcker Rule” is expected to be adopted tomorrow by the five US Federal financial regulatory agencies. Two of them —...more

Federal Reserve Board Announces BSA/AML Enforcement Action Involving International Remittances

On October 31, the Federal Reserve Board released a BSA/AML enforcement action against a Pakistani bank and its New York branch. The Written Agreement addresses examiners’ findings of alleged compliance and risk management...more

Federal Reserve Board Announces BSA/AML Compliance Action

On October 17, the Federal Reserve Board released a cease and desist order against a foreign bank and its New York branch over alleged BSA/AML compliance failures. After entering into a Written Agreement in June 2012 that...more

Special Alert: Agencies Issue Joint Statement On Fair Lending Compliance And The CFPB’s ATR/QM Rule

On October 22, the CFPB, the OCC, the FDIC, the Federal Reserve Board, and the NCUA (collectively, the Agencies) issued a joint statement (Interagency Statement) in response to inquiries from creditors concerning their...more

Orrick's Financial Industry Week in Review - August 19, 2013

CFPB Update on Mortgage Regulation Exam Procedures - On August 15, the CFPB released a second update to its exam procedures in connection with mortgage regulations to cover: (i) ability-to-repay; (ii) qualified...more

CFPB, Federal Reserve Board, DOJ Plan Indirect Auto Fair Lending Compliance Event

On July 15, the Federal Reserve Board announced that it will co-host an upcoming consumer compliance webinar with the CFPB and the DOJ entitled “Indirect Auto Lending – Fair Lending Considerations.” ...more

Federal Reserve, OCC and FDIC Propose Higher Capital Requirements for Largest Banks

On July 9, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (collectively, the Agencies) issued a joint notice of proposed...more

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