Office of the Comptroller of the Currency

News & Analysis as of

Prudential Regulators Finalize Liquidity Coverage Ratio Rule

On September 3, the OCC, the FDIC, and the Federal Reserve Board released a final rule establishing a minimum liquidity requirement for large and internationally active banking organizations. The rule will require banking...more

Prudential Regulators Seek Comments On Proposed CRA Questions And Answers

On September 8, the OCC, the FDIC, and the Federal Reserve Board released proposed revisions to the Interagency Questions and Answers Regarding Community Reinvestment. Specifically, the agencies propose to revise three...more

Prudential Regulators Finalize Supplementary Leverage Ratio Rule

On September 3, the OCC, the FDIC, and the Federal Reserve Board released a final rule that modifies the definition of the denominator of the supplementary leverage ratio in a manner consistent with recent changes agreed to...more

Financial Services Report - Fall 2014

In This Issue: - Beltway Report - Bureau Report - Mobile and Emerging Payments Report - Mortgage and Fair Lending Report - Operations Report - Preemption Report - Privacy...more

Banking Agencies Request Comment on Proposed Questions and Answers Regarding Community Reinvestment

On September 8, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency requested comment on proposed revisions to the “Interagency...more

Is Your Bank Stressed Out? OCC Follows Fed on Proposed Stress-Test Changes

On September 10, the Office of the Comptroller of the Currency (“OCC”) published proposed revisions to its information collecting regulations related to the Dodd-Frank Act’s “stress test” for large national banks and federal...more

OCC Issues Final Rule on Heightened Expectations

According to the final rule recently issued by the Office of the Comptroller of the Currency (OCC) formalizing the agency’s “heightened expectations” supervisory regime, the largest U.S. federally chartered depository...more

LIHTC discrimination suit filed against federal government

A lawsuit was recently filed alleging that the U.S. Department of Treasury (Treasury) and Office of Comptroller of the Currency (OCC) perpetuated racial segregation in the City of Dallas in their administration of the Low...more

Treasury Department and OCC Sued for Discriminatory Conduct in LIHTC Program

A lawsuit was recently filed alleging that the U.S. Department of Treasury (Treasury) and Office of Comptroller of the Currency (OCC) perpetuated racial segregation in the City of Dallas in their administration of the Low...more

OCC Updates Electronic Fund Transfer Act Booklet

On August 28, the OCC issued Bulletin 2014-43, which announces the issuance of a revised “Electronic Fund Transfer Act” booklet of the Comptroller’s Handbook. This booklet replaces the similarly titled booked issued in...more

Fear of Heights? OCC Adopts Heightened Standards for Risk Governance of Large Institutions

Wasting no time in leaving summer behind, on September 2, 2014, the Office of the Comptroller of the Currency (OCC) adopted Final Guidelines, to be published soon in the Federal Register, establishing risk governance...more

Federal Banking Regulators Finalize Liquidity Coverage Ratio

On September 3, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency finalized a rule to strengthen the liquidity positions of large financial institutions.The...more

OCC Finalizes Heightened Standards for Large Financial Institutions

On September 2, the OCC published its final guidelines to purportedly strengthen the governance and risk management practices of large financial institutions. The guidelines provide that covered institutions should establish...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

OCC Issues Final Guidelines Calling for Heightened Standards for Governance and Risk Management of Large Financial Institutions

The OCC issued final guidelines (the “Final Guidelines”) that call for strengthened governance and risk management practices at the following categories of large financial institutions with $50 billion or more in average...more

Comments requested regarding proposed guidance on the Community Reinvestment Act

The Office of the Comptroller of the Currency, Treasury, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation are the federal agencies that implement the Community Reinvestment...more

Banking Agencies Adopt Supplementary Leverage Ratio Final Rule

On September 3, the Federal Reserve Board, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency adopted a final rule modifying the definition of the denominator of the supplementary...more

AABD Makes Suggestions to Regulatory Agencies Regarding The Burdens Placed On America’s Bank Directors

On September 2, David Baris, President of the American Association of Bank Directors (AABD) and a Partner at BuckleySandler LLP, and Richard Whiting, Executive Director of the AABD, submitted a comment letter to the Nation’s...more

OCC Finalizes its Heightened Standards for Large Financial Institutions

On September 2, the OCC published final guidelines to strengthen the governance and risk management practices of large financial institutions. The guidelines apply to insured national banks, insured federal savings...more

Federal Banking Regulators Finalize Liquidity Coverage Ratio

On September 3, the FDIC, the Fed, and the OCC finalized the Liquidity Coverage Ratio rule to strengthen the liquidity positions of large financial institutions. The rule will for the, first time, create a standardized...more

Federal Agencies Seek Comment on Swap Margin Requirements

On September 3, the Fed, the Farm Credit Administration, the FDIC, the FHFA, and the OCC sought comment on a proposed rule to establish margin requirements for swap dealers, major swap participants, security-based swap...more

Orrick's Financial Industry Week in Review

ESMA Publishes Guidelines on the EU Implementation of CPSS-IOSCO Principles - On September 4, ESMA published the translation of guidelines and recommendations on implementing the principles for financial market...more

Summary of Prudential Regulators’ Re-Proposed Margin Rules

On September 3, the Board of Governors of the Federal Reserve System (“Board”), the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the Farm Credit Administration and the Federal Housing...more

Interagency Guidance Regarding Unfair Or Deceptive Credit Practices

On August 22, the CFPB and the federal banking agencies (Fed, OCC, FDIC and NCUA) issued interagency guidance regarding unfair or deceptive credit practices (UDAPs). The guidance clarifies that “the repeal of the credit...more

Is a Uniform Debt Buying Code on Its Way?

The Uniform Law Commission (ULC), a non-partisan organization committed to drafting uniform state laws, has authorized the formation of a committee to study the need for and feasibility of state legislation to address the...more

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