News & Analysis as of

Focus on Incentive Pay Practices?: A Message from the Regulators

Incentive pay is an important part of compensation packages. It allows employers to reward those employees who perform well (and show those employees who do not that under-performing will have negative consequences). ...more

Agencies announce submission of diversity self-assessments to OMWIs can begin

In a notice to be published in tomorrow’s Federal Register, the CFPB, OCC, Fed, FDIC, SEC, and NCUA announce that the Office of Management and Budget has approved the “information collection” contained in their “Final...more

Agencies Invite Comment on Proposed Rule to Prohibit Incentive-Based Pay that Encourages Inappropriate Risk-Taking in Financial...

On May 16, 2016, six federal agencies – the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Federal Reserve Board of Governors, the National Credit Union Administration, the Office of the...more

Regulators Issue New Guidance on Expectations of Deposit Reconciliations: Beware of the UDAAP Implications

In response to a recent consent order against a depository institution and several other examinations of major banks, five federal financial regulators have issued an inter-agency guidance ensuring that depository...more

Banking Agencies Issue Deposit-Reconciliation Best Practices

Five federal regulators on Wednesday – the FDIC, the Fed, CFPB, NCUA, and OCC – issued an interagency guidance applicable to all FDIC-supervised financial institutions describing expectations for effective...more

Financial Regulators Explain Their Expectations for Deposit Reconciliation

This week, the Federal Reserve Board, CFPB, FDIC, NCUA and OCC issued guidance regarding the agencies' supervisory expectations for deposit reconciliation on consumer accounts. The agencies summarized their observations on...more

The SEC is Seeking Comment on a Joint Agency Proposed Rule Relating to Incentive-based Compensation Arrangements

On May 6, 2016, the Office of the Comptroller of the Currency, Treasury (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), Federal Housing Finance Agency...more

CFPB issues guidance on deposit reconciliation practices

The CFPB and four other agencies have issued “Interagency Guidance Regarding Deposit Reconciliation Practices.”  The other agencies are the OCC, Fed, FDIC, and NCUA.  The guidance is intended to set forth the agencies’...more

Take Two: Incentive-Based Payment Arrangements Rule Reappears

For a second time, federal banking regulators are seeking comment on a jointly proposed rule that would impose restrictions on incentive-based pay arrangements....more

New Proposed Rules on Curbing Wall Street Incentive Compensation

Six federal agencies (the "Agencies") consisting of: the Federal Deposit Insurance Corporation ("FDIC"), National Credit Union Administration ("NCUA"), Federal Housing Finance Agency ("FHFA"), Office of the Comptroller of the...more

Federal Regulator Issues Proposed Rule Aimed at Incentive Compensation Policies of Banking Organizations

On April 21, 2016, the National Credit Union Administration (collectively, with the Office of the Comptroller of the Currency, Treasury, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation,...more

Revised Rules on Dodd-Frank Incentive Compensation Requirements for Financial Institutions Proposed

If adopted, the Proposed Rule would have a significant impact on compensation practices at covered institutions. On April 21, 2016, the National Credit Union Administration (the NCUA) issued a proposed rule regarding...more

New Proposed Rules on Banker Incentive Compensation Released

The National Credit Union Administration, or NCUA, became the first of six Agencies to unveil a revised rule proposal under Section 956 of the Dodd-Frank Act: prohibiting incentive-based payment arrangements that the...more

Interagency Guidance: CIP Requirements Apply to Certain Prepaid Cards

On March 21, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency (OCC), and the U.S. Department of...more

FFIEC Weighs in on Cybersecurity in Light of Unprecedented Risk of Cyber Threats

As financial institutions of all sizes continue to face unprecedented cybersecurity risk, the Federal Financial Institutions Examination Council (FFIEC) released its Cybersecurity Assessment Tool. The Assessment is...more

Protecting financial institutions in cyberspace—U.S. financial regulators come up with a new tool kit to stem cyberthreats

The Federal Financial Institutions Examination Council (FFIEC) has recently developed a new tool to help U.S. financial institutions combat the increasing volume and sophistication of cyber attacks. To blunt threats to a...more

Dodd-Frank and Diversity

As the dust settles on the recent final interagency policy statement, employers should discuss with qualified counsel how to develop and encourage a diversity and inclusion strategy within the existing law....more

Regulators Issue Final Dodd-Frank Standards for Assessing Diversity Policies and Practices of Covered Entities in the Financial...

On June 9, 2015, six federal agencies (“Agencies”) subject to the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (“Act”) issued much-anticipated joint final standards (“Final Standards”) in accordance with...more

FFIEC Releases Cybersecurity Assessment Tool

Why it matters - As anticipated, the Federal Financial Institutions Examination Council (FFIEC) released its Cybersecurity Assessment Tool, providing a process for financial institutions' management to gauge their...more

FFIEC Cybersecurity Assessment Tool: Not Just For Financial Institutions

On June 30, 2015, the Federal Financial Institutions Examination Council (FFIEC) released its long anticipated Cybersecurity Assessment Tool (press release here). The FFIEC is a formal interagency organization empowered to...more

FFIEC’s Cybersecurity Assessment Tool: Guidance for CEOs and Boards - Senior Management and Boards Should Be Actively Addressing...

The Federal Financial Institutions Examination Council (FFIEC) released a Cybersecurity Assessment Tool (CAT) on June 30, 2015, to assist organizations in identifying cyber risks and assessing their cybersecurity...more

FFIEC’s Cybersecurity Assessment Tool: Guidance for CEOs and Boards - Senior Management and Boards Should Be Actively Addressing...

The Federal Financial Institutions Examination Council (FFIEC) released a Cybersecurity Assessment Tool (CAT) on June 30, 2015, to assist organizations in identifying cyber risks and assessing their cybersecurity...more

New 2015 Laws Update Data Breach and Identity Theft in Washington and Oregon - Both States Set New Requirements for Notifying...

Washington and Oregon both recently updated laws that define data security and incident response requirements for breaches of consumers’ personal information. Details of these new requirements for each state are...more

CFPB issues final diversity and inclusion standards

The CFPB was among six federal agencies that issued final new diversity and inclusion standards earlier this week. The other agencies were the OCC, Fed, FDIC, NCUA and SEC. The standards go into effect on June 10, 2015 and...more

Orrick's Financial Industry Week in Review

UBS and Capital Ventures Settle RMBS Dispute - On March 26, Capital Ventures International and several UBS affiliates filed a stipulation of dismissal after reaching a settlement disposing of all claims in the action....more

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