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
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
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
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
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
On April 29, 2019, the Office of the Comptroller of the Currency (OCC) issued an Advance Notice of Proposed Rulemaking (ANPR) to solicit comment on whether it should issue a formal proposal to expand the reach of its...more
On January 24, 2017, the Office of the Comptroller of the Currency (the “OCC”) issued examination procedures to supplement its 2013 guidance Third-Party Relationships: Risk Management Guidance. The examination procedures...more
Financial Industry Developments - Class Action Against Lending Club and WebBank Headed to Defeat - On Monday, January 31, 2017, a federal district court in the Southern District of New York granted a motion to...more
The Office of the Comptroller of the Currency (OCC) last week released proposed amendments to its Part 30 regulations, which reflect the agency’s “heightened expectations” for large banks. That release, styled as an “Interim...more
The Federal Financial Institutions Examination Council (“FFIEC”) issued final Guidance on December 11, 2013 concerning the risks faced by banks, savings associations, and credit unions when offering their services through...more
On December 11, 2013, the Federal Financial Institutions Examination Council (the “FFIEC”), on behalf of its members (the OCC, FRB, FDIC, NCUA and the Consumer Financial Protection Bureau (“CFPB”)), released final guidance...more
The Office of the Comptroller of the Currency (OCC) recently issued a new Bulletin 2013-29 containing substantially more onerous risk management guidance for third-party business relationships (3PRs) of national banks and...more
On October 30, 2013, the OCC published a broad update of its guidance regarding national banks and their third-party relationships. The guidance also applies to federal savings associations (“FSAs”) as well as extending...more