Discrimination and Bias in Residential Lending
The Importance of Assessment Areas
In This Issue. The Federal Deposit Insurance Corporation (FDIC) is seeking information and comment regarding the FDIC’s supervisory approach to examinations during the pandemic; the FDIC’s tech lab, FIDTECH, announced a “tech...more
In This Issue. The Securities and Exchange Commission (SEC) adopted amendments to its exemptive applications procedures under the Investment Company Act of 1940, as amended (the 1940 Act) and proposed to amend Form 13F to...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
The U.S. Federal Financial Institutions Examination Council members released a joint statement with respect to cyber insurance and its role in risk management. FFIEC members include the U.S. Board of Governors of the Federal...more
The Federal Financial Institutions Examination Council (FFIEC) has issued a joint statement emphasizing the need for lenders and servicers to include cyber insurance in their risk management program. Although the FFIEC did...more
The Federal Financial Institutions Examination Council (FFIEC) has issued a joint statement providing guidance for financial institutions about the role of cyber insurance in risk management of informational technology...more
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
On May 31, 2017, the Federal Financial Institutions Examination Council (FFIEC) released an update to its Cybersecurity Assessment Tool. The Cybersecurity Assessment Tool was originally released by the FFIEC in June of...more
This blog is the first in a series of articles which will examine the risks, rewards, innovative uses, and changing legal landscape of social media use by financial services institutions. Future blog articles will examine...more
FDIC bank examinations generally include a focus on the IT systems of banks with a particular focus on information security. The federal banking agencies issued Interagency Guidelines Establishing Information Security...more
In December 2016, Thomas Curry, the Comptroller of the Currency, stated that cybersecurity was the single greatest systemic threat to our financial system. He was not being hyperbolic. Cybersecurity should be on...more
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
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
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
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
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
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
On June 7, 2016, the Federal Financial Institutions Examination Council (FFIEC) reminded banks of the cyber risks associated with interbank messaging and wholesale payment networks. FFIEC made its announcement after hackers...more
In February 2016, hackers stole $81 million from the Bangladesh central bank by sending fraudulent messages through the Society for Worldwide Interbank Financial Telecommunication (SWIFT) messaging system. Three months...more
A new set of federal banking regulations are on the horizon aimed at helping financial institutions put in place minimum compliance standards to prevent future cyber-attacks. Bloomberg Law has reported that the Federal...more
The Federal Financial Institutions Examination Council (FFIEC) reiterated the importance of banks protecting themselves from cyber attacks in a newly issued statement, urging financial institutions to "actively manage the...more
Not surprisingly, cybersecurity remains a top examination priority for the Comptroller of the Currency (“OCC”). And that means national banks and federal savings associations – and their leadership teams – should be prepared...more
The Nutter Bank Report is a monthly publication of the firm's Banking and Financial Services Group. Headlines - 1. DOB Revises Guidance on Branch and Main Office Notices and Applications - 2. FDIC Updates...more
Cyber-risk is a witch’s brew of reputational, operational, legal and financial dangers. This toxic combination exposes a financial institution to a potentially existential hazard when an intrusion occurs. The only way to...more
Earlier this summer, the Federal Financial Institutions Examination Council (FFIEC) released its highly anticipated Cybersecurity Assessment Tool (Assessment), which is designed to assist financial institutions in identifying...more