Discrimination and Bias in Residential Lending
The Importance of Assessment Areas
The OCC, FDIC, NCUA and Fed have adopted a new Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts. The new policy statement updates, expands on and supersedes existing guidance from 2009,...more
In this Issue. The U.S. Securities and Exchange Commission’s (SEC) Division of Examinations recently published a risk alert spotlighting observations from its “RIC Initiatives”; the Federal Financial Institutions Examination...more
Senators Inquire about CFPB’s Fintech Agenda - On July 27, 2021, Senator Sherrod Brown, the Chairman of the U.S. Senate Committee on Banking, Housing, and Urban Affairs, sent a letter to the Consumer Financial Protection...more
On August 11, the Federal Financial Institutions Examinations Council (FFIEC) issued new guidance, providing examples of effective authentication and access risk management principles and practices for financial institutions....more
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
The Federal Financial Institutions Examination Council (FFIEC) has issued new guidance on authentication and access titled, “Authentication and Access to Financial Institution Services and Systems” (Guidance.) The Guidance...more
President Biden Issues an Executive Order on Competition with Implications for Financial Institutions - On July 9, 2021, President Biden issued an Executive Order on Promoting Competition in the American Economy. The...more
Vendor management is a complex task, yet a necessary undertaking for any organization dealing with third parties. ...more
On August 3, 2020, the Federal Financial Institutions Examination Council1 (FFIEC) issued a new joint statement of principles for banks to consider while working with their loan customers as the end of COVID-19 initial loan...more
On August 3, 2020, the Federal Financial Institutions Examination Council (“FFIEC”) issued a joint statement to provide prudent risk management and consumer protection principles for financial institutions to consider when...more
The Federal Financial Institutions Examination Council (FFIEC) on behalf of its members issued a statement on August 3 setting forth prudent risk management and consumer protection principles for financial institutions as...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
On April 30, 2010, the Federal Financial Institutions Council (FFIEC) issued Guidance on the use of cloud computing services and security risk management principles in the financial services sector. The Guidance reminds...more
Over the past two weeks, we have received numerous inquiries from financial institutions on what actions should be taken or considered to address the COVID-19/Coronavirus pandemic. While every bank is different and the...more
As members of the financial industry prepare to meet the challenges associated with COVID-19, key government agencies have begun to offer guidance with respect to how their regulated financial institutions, including...more
In This Issue. The Federal Deposit Insurance Corporation (FDIC) released a new guide to help financial technology companies and others partner with banks; the Financial Industry Regulatory Authority (FINRA) announced that it...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
The Tale of an AML BSA Exam Gone Wrong - As we have blogged, the Ninth Circuit Court of Appeals recently upheld the decision of the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) to issue a cease...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
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