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News & Analysis as of

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

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

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

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

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

Orrick's Financial Industry Week in Review

The Federal Housing Administration Announces New Loan Limits for 2016 - On December 9, 2015, the Federal Housing Administration ("FHA") announced its schedule of loan limits for the 2016 calendar year. The new schedule,...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

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

House Republicans ask CFPB and banking agencies to disclaim “Operation Choke Point”

Six Republican members of the House Financial Services Committee, including Chairman Jeb Hensarling, have sent identical letters to the CFPB, OCC, Fed and NCUA asking each agency to “publicly disclaim [its] past, present, and...more

CFPB seeks information from industry on student loan modification options and issues guidance on private student loans with ...

As a follow up to a January 2014 meeting with private student loan lenders and servicers convened by Director Cordray and Education Secretary Arne Duncan, the CFPB sent letters last week to certain “market participants”...more

Regulators Release Guidance on Private Student Loans With Graduated Repayment Terms at Origination

On January 29, the federal financial regulatory agencies (the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union...more

Banking and Financial Services E- Note - December 2014

In This Issue: - Congress Move to Roll Back Bank 'Push-Out' Regulation Meets Anger - NCUA Calls for Retailers to Cover Data Breach Costs - Regulators Propose 8 Biggest Banks Increase Capital...more

Agencies Request Comment on Proposed Flood Insurance Rule

Five federal regulatory agencies on October 24 announced the approval of a joint notice of proposed rulemaking to amend regulations pertaining to loans secured by property located in special flood hazard areas. The proposed...more

What’s Unfair is Unfair: Repeal of Reg AA May Have Little Practical Effect

The Federal Reserve Board (Board) issued a notice of proposed rulemaking on August 22, 2014 (Notice) for the repeal of Regulation AA, which is the Board’s credit practices rule prohibiting certain unfair or deceptive acts and...more

Agencies Issue Statement on Increased Maximum Flood Insurance Coverage for Other Residential Buildings

The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Farm Credit Administration, the National Credit Union Administration, and the Federal Deposit Insurance Corporation...more

New Social Media Guidance for Financial Institutions (Which Might Include You)

The latest extension of the social media puzzle involves financial institutions. But, banks are not the only financial institutions governed by the alphabet soup of regulatory organizations addressing financial services (the...more

FFIEC Issues Joint Statements on DDoS Cyber-Attacks and Cyber-Attacks on ATM and Card Authorization Systems

On April 2, 2014 the members of the Federal Financial Institutions Examination Council (“FFIEC”) issued two joint statements: the first joint statement regards distributed denial-of-service (“DDoS”) attacks, and the second...more

Federal Regulators Issue Proposal on Minimum Requirements for Appraisal Management Companies

Collectively, the FDIC, the OCC, FRB, CFPB, NCUA and FHFA issued a proposed rule establishing the minimum requirements for mortgage appraisal management companies. An appraisal management company is generally an entity that...more

Federal Regulators Amend Appraisal Requirements for Higher-Priced Mortgages

Collectively, the FDIC, the OCC, FRB, CFPB, NCUA, FHFA and HUD finalized the rule governing appraisal requirements for higher-priced mortgage loans. In August 2013, the federal regulators issued a proposal to amend Regulation...more

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