Office of the Comptroller of the Currency

News & Analysis as of

OCC Issues Merchant Processing Booklet

On August 20, the Office of the Comptroller of the Currency (OCC) issued the “Merchant Processing” booklet of the Comptroller’s Handbook. This booklet, which replaces the booklet of the same name issued in December 2001, has...more

OCC Updates Merchant Processing Booklet

On August 20, the OCC issued Bulletin 2014-41, which announces a new “Merchant Processing” booklet of the Comptroller’s Handbook. This booklet replaces the booklet of the same name issued in December 2001 and provides updated...more

Sleeping Giant? OCC Wakes Up to New Focus on Merchant Processing

Following hard on the heels of recent risk management actions taken by other federal agencies, the Office of the Comptroller of the Currency (OCC) has issued a thoroughly updated booklet on Merchant Processing, which forms a...more

CFPB and federal banking agencies issue guidance on unfair or deceptive credit practices in light of Reg AA repeal

Concurrently with a proposal from the Fed to repeal Regulation AA (12 CFR part 227), the CFPB and the federal banking agencies (Fed, OCC, FDIC and NCUA) have issued interagency guidance regarding unfair or deceptive credit...more

OCC Releases Revised Comptroller’s Handbook

On August 20, the OCC released an updated booklet providing guidance to examiners and bankers on assessing and managing the risks associated with merchant processing activities. ...more

Orrick's Financial Industry Week in Review

Financial Stability Board Publishes Responses to Consultation on Proposed Reforms of the Forex Market - On August 20, the Financial Stability Board (FSB) published responses to its consultation in respect of proposed...more

Recent Developments in Acquisition Finance

Several recent legal and regulatory developments in the U.S. will likely alter the makeup of the group of arrangers and financiers willing to arrange and provide financing for certain highly leveraged transactions, and also...more

Corporate and Financial Weekly Digest - Volume IX, Issue 33

In this issue: - ISS Launches New Equity Plan Data Verification Portal - ISDA Publishes Protocol for 2014 Credit Derivatives Definitions - FinCEN Issues Advisories for US Financial Institutions -...more

OCC steps up SCRA focus in exams

As we have been reporting, the CFPB has made the Servicemembers Civil Relief Act (SCRA) a major focus and instructs its examiners to look at SCRA compliance during examinations. The OCC has also stepped up its focus on SCRA...more

OCC Issues Lease Financing Booklet of the Comptroller’s Handbook and Rescinds Earlier Publication

On August 12, the Office of the Comptroller of the Currency (OCC) issued the “Lease Financing” booklet of the Comptroller’s Handbook. This updated booklet replaces a similarly titled booklet issued in January 1998. The...more

OCC Increases Semiannual Assessment for Larger National Banks and Federal Savings Associations

On August 11, the Office of the Comptroller of the Currency (OCC) issued a final rule that increases the OCC’s semiannual assessment on national banks and federal savings associations (banks) with more than $40 billion in...more

Corporate and Financial Weekly Digest - Volume IX, Issue 32

In this issue: - SEC’s Office of Investor Education and Advocacy Releases Alert on Identifying Fraudulent Private Placements - ICE Futures U.S. Issues Amendments to EFRP Rule and FAQs - Consumer Financial...more

OCC Issues New Debt Sale Guidance

On August 4, the OCC issued Bulletin 2014-37, which provides new guidance on the application of consumer protection requirements and safe and sound banking practices to consumer debt-sale arrangements with third parties—e.g....more

FRB Interpretive Letter Grants Individual an Exemption from the Major Assets Prohibition of the Interlocks Act

The FRB recently issued an interpretive letter (the “FRB Letter”) in which the FRB granted an individual director (the “Director”) an exemption from the prohibition of the Depository Institution Management Interlocks Act (the...more

OCC Issues Bulletin That Discusses the Characteristics of and Supervisory Considerations Concerning Mutual Federal Savings...

On July 22, 2014, the OCC issued a bulletin (OCC Bulletin 2014-35, the “Bulletin”) in which the OCC describes the special characteristics of mutual federal savings associations (“Mutual FSAs,” and, collectively with...more

Orrick's Financial Industry Week in Review

Fed Issues Report on the Economic Well-Being of U.S. Households - On August 7, the Fed provided a snapshot of the self-perceived financial and economic well-being of U.S. households and the issues they face, based on...more

OCC Publishes Final Rule that Revises the Risk-Based Capital Definition of Eligible Guarantee for Advanced Approaches Banks

The OCC, the Fed, and the FDIC have published a final rule that revises the advanced approaches risk-based capital rules by removing the requirement that only guarantees provided by certain counterparties are eligible for...more

OCC consumer protection standards in new Bulletin may influence CFPB Debt Sales Examinations of Banks

As noted in our recent Alert, the Office of the Comptroller of the Currency (OCC) has issued Bulletin 2014-37 on Consumer Debt Sales (the “Bulletin”). The Bulletin addresses the application of consumer protection requirements...more

New OCC Guidance on Debt Sales

On August 4, 2013, the Office of the Comptroller of the Currency (“OCC”) released new guidance to (Bulletin 2014-37) regulated entities on the application of consumer protection requirements and safe and sound banking...more

CFPB releases more overdraft program data as a prelude to likely rulemaking

The CFPB moved closer to likely rulemaking on overdraft programs with the release late last week of a new report entitled “Data Point: Checking account overdraft.” The report is based on account-level and...more

OCC Report Highlights Risks Linked to Evolving Cyberthreats

According to the latest semi-annual risk report issued by the U.S. Office of the Comptroller of Currency (OCC), new methods of money laundering and a growth in both the volume and sophistication of electronic banking fraud...more

Dodd-Frank News: July 2014 Dodd Frank Wall Street Reform and Consumer Protection Act Update

In This Issue: - Recent Cases ..RESPA ..FDCPA ..TCPA ..FCCPA & FDCPA ..TILA - In The News ..CFPB to Begin Collecting Complaints Regarding Prepaid Cards ..CFPB Proposes Letting...more

OCC Report Lists Key Risks For Review In Upcoming Examinations

Highlighting the operational, strategic, and compliance risks confronting financial institutions, the Office of the Comptroller of the Currency (OCC) published its “Semiannual Risk Perspective” report in late June based on...more

FDIC Proposes Changes to Assessments Rule

On July 15, the Federal Deposit Insurance Corporation (FDIC) proposed (1) to revise the ratios and ratio thresholds for capital evaluations used in its risk-based deposit insurance assessment system (the FDIC stated this was...more

FDIC Proposes Rule to Revise Deposit Insurance Assessments to Reflect the Basel III Capital Rule

The FDIC issued a notice of proposed rulemaking (the “Proposed Rule”) that would revise the FDIC’s risk-based deposit insurance assessment system to reflect the final Basel III capital rule (the “Final Capital Rule”) adopted...more

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