News & Analysis as of

Office of the Comptroller of the Currency

Financial Services Weekly News - August 2017 #3

by Goodwin on

Editor's Note - In This Issue. The Department of Labor (DOL) filed a Notice of Administrative Action seeking to delay the Fiduciary Rule until July 2019; federal banking agencies issued guidance on the capital treatment of...more

The OCC Takes Initiative on Seeking Public Comment for Changes to the Volcker Rule

by Shearman & Sterling LLP on

The Office of the Comptroller of the Currency (OCC), which regulates national banks and, as such, is responsible for administering the Volcker Rule with respect to the largest banking entities in the United States, has...more

Regulators Begin Volcker Rule Review, Signalling Potential for Needed Clarifications

by White & Case LLP on

The Office of the Comptroller of the Currency ("OCC") has issued a notice and request for public input ("Request") on potential revisions to the implementing regulations for the Volcker Rule. The OCC's action represents a...more

Court Decision May Slow SEC Approval of SRO Rules

The SEC must generally approve rules and rule changes by self-regulatory organizations, which are referred to as SROs. According to this SEC web page, there are 37 active SROs. The volume of rule filings submitted for...more

Volcker Rule Reform Begins

by Jones Day on

The Situation: The Volcker Rule's complexity has created uncertainty and compliance burdens that adversely affect market liquidity, risk hedging, and other economically important activities. The Opportunities: Bank...more

Orrick's Financial Industry Week In Review

OCC Solicits Public Comments on Revising the Volcker Rule - On August 2, 2017, the Office of the Comptroller of the Currency ("OCC") issued a public notice that it is seeking public input on revising the final regulation...more

OCC Solicits Public Comments on Revising the Volcker Rule

On August 2, 2017, the Office of the Comptroller of the Currency (“OCC“) issued a public notice that it is seeking public input on revising the final regulation implementing section 619 of the Dodd–Frank Wall Street Reform...more

Financial Services Weekly News - August 2017 #2

by Goodwin on

Editor's Note - In This Issue. The Consumer Financial Protection Bureau (CFPB) released prototypes of “Know Before You Owe” overdraft disclosure forms and provided an updated rulemaking agenda for 2017; the Federal Reserve...more

OCC Report Highlights Top Risks for Banks

What are the top risk areas for national banks and federal savings associations? According to the Office of the Comptroller of the Currency’s (OCC) Semiannual Risk Perspective for Spring 2017, there are four: strategic,...more

Process to Scale Back the Volcker Rule Begins

On August 2, the Office of the Comptroller of the Currency (OCC) issued a notice (the OCC Notice) seeking public comments over the next 45 days to assist in determining how the final rule implementing Section 13 of the Bank...more

OCC files renewed motion to dismiss state regulators’ challenge to fintech company special purpose national bank charter proposal

by Ballard Spahr LLP on

The Office of the Comptroller of the Currency (OCC) has filed a renewed motion to dismiss the lawsuit filed by the Conference of State Bank Supervisors (CSBS) in D.C. federal district court challenging the OCC’s authority to...more

Financial Services Weekly News - August 2017

by Goodwin on

Editor's Note - In This Issue. The Office of the Comptroller of the Currency (OCC) announced that it was seeking public comments on revising the Volcker Rule; the Securities and Exchange Commission (SEC) offered a window...more

OCC Seeks Public Comment on the Volcker Rule

by Morrison & Foerster LLP on

Section 13 of the Bank Holding Company Act (the “Volcker Rule”) and its implementing regulations (the “Implementing Regulations”) generally prohibit banking entities from engaging in proprietary trading and from investing in,...more

WSGR Fintech Update - August 2017

Wilson Sonsini Goodrich & Rosati is pleased to present the August 2017 issue of the WSGR Fintech Update. This latest edition features an article on the State of Delaware's amendments to permit Delaware corporations to use...more

OCC Seeks Comment on Volcker Rule to Implement Treasury Recommendations

The Office of the Comptroller of the Currency is seeking comment to assist in determining how the final rule implementing section 13 of the Bank Holding Company Act, which is referred to as the Volcker Rule, could be revised...more

Federal Regulatory Agencies Announce Coordination of Reviews for Certain Foreign Funds Under “Volcker Rule”

On July 21, 2017, the Board of Governors of the Federal Reserve System, the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation, the Office of Comptroller of the Currency and the Securities and...more

Senate bill introduced to override Madden decision

by Ballard Spahr LLP on

Democratic Senator Mark Warner has introduced a bill, S.1642, that would override the Second Circuit’s decision in Madden v. Midland Funding. (In Madden, the Second Circuit ruled that a nonbank that purchases loans from a...more

Special Purpose National Bank Charter for FINTECH Firms

by Carlton Fields on

The office of the Comptroller of the Currency (OCC) published a draft supplement to its licensing manual, to define and tailor the requirements for FINTECH companies that apply for special purpose national bank charters. This...more

Acting OCC Comptroller Provides Update on Granting Special Purpose National Bank Charters to Fintech Companies

As previously reported, the Office of the Comptroller of the Currency (OCC) recently decided to consider applications from financial technology (fintech) companies to become special purpose national banks (SPNBs). In our May...more

Federal Banking Agencies Announce No-action Position on Certain Foreign Excluded Funds Under the Volcker Rule

by Morrison & Foerster LLP on

Section 13 of the Bank Holding Company Act of 1956, as amended, and its implementing regulations (the “Volcker Rule”) generally prohibit a “banking entity” from engaging in proprietary trading and from investing in,...more

New CFPB Arbitration Rule Already Under Attack

On July 10, 2017, the Consumer Financial Protection Bureau (CFPB) issued a new rule that would make it easier for consumers to bring class action lawsuits against financial institutions. The new rule bans financial...more

Acting Comptroller Endorses Fintech Charters

by Morrison & Foerster LLP on

In July 19, 2017 remarks prepared for delivery to the Exchequer Club in Washington, D.C., Acting Comptroller of the Currency Keith Noreika expressed his support for the Office of the Comptroller of the Currency’s (“OCC”)...more

FINRA Holds Regulator Forum on Distributed Ledger Technology

On July 13, 2017, the Financial Industry Regulatory Authority, Inc. (FINRA) held a Blockchain Symposium (the Symposium) in which representatives from a number of US regulators discussed the work they have undertaken to assess...more

Acting Comptroller Noreika confirms continued OCC interest in SPNB charter proposal for fintech companies; our thoughts on the...

by Ballard Spahr LLP on

Acting Comptroller of the Currency Keith Noreika, in remarks on July 19 to the Exchequer Club, confirmed that the OCC is continuing to consider its proposal to allow financial technology (fintech) companies to apply for a...more

OCC FinTech Charter in Trump Administration Cards

by Goodwin on

If you are wondering about the prospects of the OCC FinTech national bank charter under the Trump Administration, we got a sign yesterday. In his remarks to the Exchequer Club in Washington, D.C., President Trump’s Acting...more

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