Federal Financial Institutions Examination Council

News & Analysis as of

Cybersecurity Risk: Latest Guidance from Bank Examiners

The Office of the Comptroller of the Currency has indicated in a recent bulletin that its examiners will gradually incorporate a Cybersecurity Assessment Tool into its examinations of national banks and other institutions...more

Nutter Bank Report, November 2016

Massachusetts Voters Approve Legalization of Marijuana for Recreational Purposes - Massachusetts voters have approved a ballot initiative legalizing the use of marijuana for recreational purposes, which will become law...more

Financial Services Weekly News - November 2016 #3

Editor's Note - A Possible Blueprint for Financial Regulatory Reform in the Trump Administration. During his campaign, President-elect Trump consistently emphasized that financial regulatory reform is a critical...more

FFIEC finalizes revised consumer compliance rating system

The Federal Financial Institutions Examination Council (FFIEC), whose members include the CFPB, has finalized guidance setting forth a revised uniform interagency consumer compliance rating system (CCRS).  The revisions...more

Banking Regulators Propose Enhanced Cyber Risk Management Standards

On October 19, 2016, the Federal Reserve, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency (together, the “Prudential Regulators”) published an advance notice of proposed rulemaking...more

New Cybersecurity Reporting Requirements? FinCEN Advisory Identifies Cybersecurity Events for Financial Institutions to Report

Last week, FinCEN (Financial Crimes Enforcement Network) issued a formal Advisory to Financial Institutions and published FAQs outlining specific cybersecurity events that should be reported through Suspicious Activity...more

Bank Regulators Issue Advanced Notice of Proposed Rulemaking on Cyber Risk Governance and Management Regulations

More regulators (apart from the FTC) are now taking note of cybersecurity issues in the financial services industry and are taking steps to protect the industry and its consumers. Earlier this year, the Consumer...more

FFIEC Releases Answers To FAQs About Cybersecurity Assessment Tool

On October 17, 2016, the Federal Financial Institutions Examination Council (“FFIEC” or the “Council”) released a set of answers to frequently asked questions about its cybersecurity assessment tool (the “CAT”). The FFIEC, an...more

FFIEC Issues FAQs on the Cybersecurity Assessment Tool

On October 18, 2016, the Federal Financial Institutions Examination Council (FFIEC) issued answers to frequently asked questions (FAQs) to clarify points in FFEIC’s Cybersecurity Assessment Tool (Assessment). FFIEC released...more

FDIC Releases Revised MLA Exam Procedures and Sets Supervisory Expectations

On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The revised procedures...more

Federal Banking Agencies Propose New Requirements for Managing Cyber Risk

Three federal banking agencies have announced plans to develop new rules that would establish cyber risk management and resiliency standards for large interconnected entities under the agencies' supervision, as well as those...more

New York's New Cybersecurity Rules: What Is Required?

The new cybersecurity rules proposed by the New York State Department of Financial Services require financial services institutions to have extensive cybersecurity protections in place; including cybersecurity programs,...more

FFIEC to Host Webinars on Mobile Financial Services and the FS-ISAC to Promote Bank Cybersecurity Preparedness

On October 6, 2013, the Federal Financial Institutions Examination Council (FFIEC) announced that it will host two webinars with the goal of increasing cybersecurity preparedness by its member financial institutions. FFIEC’s...more

FFIEC IT Security Booklet Revised

On September 9, 2016 the Federal Financial Institution Examination Council (FFIEC) updated its Information Security Booklet (available here). In addition to certain editorial non-substantive changes, the modifications...more

CFPB and FFIEC Release Updated MLA Exam Procedures; NCAU Will Accept Reasonable and Good Faith Efforts to Comply

On September 30, the CFPB released updated examination procedures for Military Lending Act (MLA) compliance. Compliance with the final rule amending the MLA, issued by the Department of Defense (DoD) in July 2015, was...more

US Federal Financial Institutions Examination Council Revisions to Information Security Booklet

The US Federal Financial Institutions Examination Council issued a revised Information Security booklet, which is part of the FFIEC’s IT Examination Handbook. The Information Security booklet summarizes the factors necessary...more

FFIEC Offers Guidance on Information Security Exams

How will examiners review the information security programs of financial institutions? Revised guidance from the Federal Financial Institutions Examination Council (FFIEC) provides help to banks by articulating the...more

Nutter Bank Report, September 2016

The Federal Reserve Board has released a policy statement that details the framework it will follow in setting the Countercyclical Capital Buffer (“CCB”) for private-sector credit exposures located in the United States. The...more

As Goes New York So Goes The Nation? Ten Highlights From New York’s Proposed Cybersecurity Rules For Banks, Insurance and...

In a presidential election year, Americans are often reminded that “As Ohio goes, so goes the nation.” When it comes to banks, insurers and financial institutions, it may be equally true to say “As goes New York, so goes the...more

New York Raises the Bar – Will Other States Follow?

On September 13, 2016, the New York Department of Financial Services (DFS) proposed new first-in-the-nation cybersecurity regulations (Regulations) that would require banks and other financial institutions to adopt minimum...more

FFIEC Releases Updates to Information Security Booklet

The Federal Financial Institutions Examination Council (FFIEC) recently revised their Information Security Booklet. This moves the financial services industry one step closer to defining clear cybersecurity and data...more

New York proposes cybersecurity regulation aiming to protect financial services companies from criminal enterprises

The New York State Department of Financial Services (NYDFS) has set forth a proposed cybersecurity regulation for financial service companies. Announced this week by New York  Governor Andrew M. Cuomo, the proposed rule seeks...more

FFIEC Provides Concrete Guidance on Setting Up Information Security Programs

The Federal Financial Institutions Examination Council (FFIEC)—the interagency body tasked with setting uniform principals and standards for the examination of financial institutions by federal prudential regulators,...more

Federal Court Finds Depository Bank Not Liable to Third Party for Mobile Remote Deposit Capture Fraud

A recent federal court case in Illinois has addressed whether a depository bank can be held liable for negligence when its customer deposits a check by mobile remote deposit capture, and the bank fails to prevent the customer...more

Nutter Bank Report, August 2016

FDIC Proposes Expansion of Third-Party Lending Examinations - The FDIC has extended the public comment period on proposed examination guidance that would significantly expand the scope of examinations of banks’...more

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