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Federal Savings Associations Office of the Comptroller of the Currency

Goodwin

SEC Proposes Changes to Private Fund Regulation

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In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Goodwin

President Biden Signs Executive Order Addressing Climate-Related Financial Risks

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In This Issue. President Biden signed an executive order addressing climate-related financial risks; the Office of the Comptroller of the Currency (OCC) finalized a rule applicable to national banks and federal savings...more

Goodwin

OCC Reconsiders Controversial Revisions to CRA Rules

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In This Issue. The Office of the Comptroller of the Currency (OCC) announced that it will reconsider its controversial June 2020 final rule revising its Community Reinvestment Act (CRA) rules, and published its Semiannual...more

Nelson Mullins Riley & Scarborough LLP

Brian Brooks' Last Dance

So let’s dance this last dance. On Jan. 4, 2021, the Office of the Comptroller of the Currency (“OCC”) published a Chief Counsel’s Interpretative Letter (the “Letter”) ‎confirming the authority of national banks’ and federal...more

Morrison & Foerster LLP

OCC Permits National Banks And Federal Savings Associations To Use Independent Node Verification Networks And Stablecoins For...

As part of the Office of the Comptroller of the Currency’s (OCC) declared effort to keep pace with a mounting demand for faster, cheaper, and more efficient payments, and the widespread adoption of new technologies, the...more

Alston & Bird

OCC’s Final “True Lender” Rule Takes Effect

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A&B ABstract: On October 27, 2020, the Office of the Comptroller of the Currency (“OCC”) issued a noteworthy final rulemaking that sets forth when a national bank or federal savings association originates a loan and is deemed...more

Morrison & Foerster LLP

Financial Services Report – Winter 2020

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Happy post-election, post-socially-distanced Thanksgiving, and pre-New Year’s newsletter. Banks, non-banks, and FinTechs can look forward to eight days of announcements from the Biden transition team with their latkes and...more

Orrick - Finance 20/20

OCC Submitted Final Rule Clarifying When Bank is a “True Lender”

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On October 27, the Office of the Comptroller of the Currency (OCC) submitted a final rule for publication to determine when a national bank or federal savings association makes a loan to a third party and is the “true...more

White & Case LLP

OCC Finalizes True Lender Rule, Attempting to End Uncertainty around Bank-Fintech Partnership Models

White & Case LLP on

The Office of the Comptroller of the Currency (OCC) issued a final rule that creates a bright-line test to determine when a national bank or federal savings association (bank) makes a loan and is the "true lender," including...more

Nelson Mullins Riley & Scarborough LLP

OCC Finalizes its “True Lender” Test: Paving the Way for Bank & Non-Bank Partnerships

The Office of the Comptroller of the Currency (“OCC”) issued its long-anticipated final rule on Oct. 27, to establish a “simple, bright-line test” to determine when a national bank or federal savings association has made a...more

Bradley Arant Boult Cummings LLP

OCC Releases Final True Lender Rule

On October 27, 2020, the OCC released its final True Lender Rule. As discussed earlier on this blog, the OCC’s rule is designed to clarify the “true lender” doctrine, a legal test utilized by courts and regulators to...more

Buchalter

Buchalter COVID-19 Client Alert: OCC Issues Final Rule Defining “True Lender” – A Bank is the “Lender” if it is Named the Lender...

Buchalter on

On October 27, the Office of the Comptroller of the Currency issued a final rule that establishes a new standard for when a national bank or Federal savings association (“bank”) is the “true lender” in a lending arrangement...more

Ballard Spahr LLP

Hundreds comment on OCC proposed “true lender” rule

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We recently published a blog about the OCC’s proposed rule “National Banks and Federal Savings Associations as Lenders” (the “Proposed Rule”), which would clarify that a bank (or savings association) is properly regarded as...more

Morgan Lewis

OCC Allows National Banks and FSAs to Provide Cryptocurrency Custody Services

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The US Office of the Comptroller of the Currency (OCC) issued an interpretive letter on July 22 allowing national banks and federal savings associations (FSAs) to provide cryptocurrency custody services to their customers in...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - July 2020

In this issue, we discuss the new initiatives under New York's BitLicense regime that clarify and streamline the regulatory landscape for virtual currency entities doing business within the state. We also examine the...more

Nutter McClennen & Fish LLP

Fintech in Brief: OCC Authorizes National Banks and Federal Savings Associations to Offer Cryptocurrency Custody Services

On July 22, 2020, the Office of the Comptroller of the Currency (the “OCC”) issued Interpretive Letter No. 1170 (the “Letter”) authorizing national banks and federal savings associations to provide cryptocurrency custody...more

King & Spalding

OCC Issues Guidance Permitting National Banks and Federal Savings Associations to Provide Crypto Custody

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On July 22, 2020, the Office of the Comptroller of the Currency (“OCC”) published an interpretative letter regarding national banks’ and federal savings associations’ authority to provide cryptocurrency custody services for...more

Troutman Pepper

OCC Proposes Bright- Line “True Lender” Rule

Troutman Pepper on

On July 20, 2020, the Office of the Comptroller of the Currency (OCC) issued its anticipated notice of proposed rulemaking on how to determine when a national bank or federal savings association (referred to collectively as a...more

Carlton Fields

Bank Regulator Clarifies Crypto Custody Rules

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On July 22, 2020, the Office of the Comptroller of the Currency (OCC) published an interpretive letter clarifying the authority of national banks and certain federal savings associations (FSAs) to provide their customers with...more

Goodwin

Financial Services Weekly Roundup: The OCC’s True Lender Test Embraces A Simplified Solution

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC) proposed a rule that would establish that a national bank or federal savings association is the “true lender” of a loan if, as of the date of origination, the...more

Nelson Mullins Riley & Scarborough LLP

OCC Moves Forward on True Lender Test

As anticipated, on July 20, 2020, the Office of the Comptroller of the Currency (“OCC”) proposed rulemaking to determine that when a national bank or federal savings association makes a loan it is the “true lender,” when...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2020

The FDIC and OCC have issued new guidance for banks on heightened cybersecurity risks facing the financial services industry because of increased geopolitical tensions and threats of aggression. The guidance published on...more

Troutman Pepper

Description Of The Small Business Investment Company Program Participation By Unleveraged Funds - January 2020

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A Small Business Investment Company (SBIC) is a privately owned and operated company that makes long-term investments in American small businesses and is licensed by the United States Small Business Administration (SBA)....more

Nutter McClennen & Fish LLP

Bank Report: October 2019

Federal Banking Agencies Adopt Simplified Capital Calculation for Community Banks The federal banking agencies have issued a final rule that will simplify capital requirements for community banks by allowing them to adopt...more

Orrick - Finance 20/20

Amendments to the Stress Testing Rule for National Banks and Federal Savings Associations

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On October 10, the OCC published a final rule in the Federal Register that will amend the OCC’s stress testing rule at 12 CFR 46. The final rule implements requirements imposed by section 401 of the Economic Growth,...more

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