Office of the Comptroller of the Currency

News & Analysis as of

FCC Delays Effective Date of Oklahoma Tribal Lifeline Change to June 8

This past Tuesday, the FCC’s Wireline Competition Bureau issued an Order delaying for 120 days the effective date of the agency’s new interpretation of “former reservations in Oklahoma” for purposes of delineating the area in...more

Financial Services Weekly News - February 2015

Regulatory Developments - FDIC Provides Framework for Cybersecurity in Recent Supervisory Insights - The FDIC featured an article titled “A Framework for Cybersecurity” in the Winter 2015 issue of Supervisory...more

Interagency CRE Guidance Update

In the ancient world kings and emperors regularly sought advice from the Oracle at Delphi when making important decisions. The Oracle would respond to questions, sometimes in poetry, other times in prose, in a manner that...more

Financial Services Weekly News - January 2016 #4

Regulatory Developments - Under Review: Deposit Insurance Assessments for Small Banks - On Jan. 21, the FDIC approved revised proposed rules on risk-based federal deposit insurance assessments for small banks...more

Regulators Caution Banks About CRE Lending

Why it matters - In a statement expressing concern about the growth of commercial real estate (CRE) lending, the federal banking agencies stressed the need to utilize "prudent risk-management practices." The Board of the...more

Surprises in OCC's Examination Priorities for 2016? Careful Innovation, Cybersecurity, Criminal Avoidance, Nonbank FI Lending

Why it matters - Comptroller Thomas J. Curry underscored key 2016 supervisory concerns for his agency in a mid-December industry call discussing the OCC's latest Semiannual Risk Perspective report. His list includes the...more

Privacy & Data Security Advisory: The Importance of Strategic Vendors in Breach Response

Cybercrime and data security incidents are on the rise. Publicized cyber incidents have become so prevalent that it would be difficult to find someone who has not received at least one breach notification letter in the mail....more

"Banking Regulators Increasingly Assert Jurisdiction Beyond Financial Institutions"

Federal and state banking regulators have broad and largely discretionary supervisory and enforcement powers over the financial institutions they regulate, which include banks and their affiliates. Key regulators in this area...more

Seller Beware: Lessons Learned from 2015 Deceptive Advertising Enforcement in the Consumer Finance Space

Federal regulators took a close look at advertisements for consumer financial products and services in 2015, bringing over 25 enforcement actions totaling over $975 million in penalties and consumer redress. In the majority...more

Preparing for Potential Inquiries into Designated Lender Counsel in PE Sponsored Syndicated Loans

Recent media reports have expressed alarm at the use of “designated lender counsel” in private equity-sponsored leveraged loan transactions. The phrase refers to the practice of a private equity firm instructing the...more

Preparing for Potential Inquiries into Designated Lender Counsel in PE Sponsored Syndicated Loans

Recent media reports have expressed alarm at the use of "designated lender counsel" in private equity-sponsored leveraged loan transactions. The phrase refers to the practice of a private equity firm instructing the...more

OCC’s Cybersecurity Regulatory Expectations: A Call to Action

Not surprisingly, cybersecurity remains a top examination priority for the Comptroller of the Currency (“OCC”). And that means national banks and federal savings associations – and their leadership teams – should be prepared...more

OCC Releases Semiannual Risk Perspective Report

On December 16, the OCC released its Semiannual Risk Perspective report to provide an overview of supervisory concerns for the federal banking system, including operational and compliance risks. According to the report, which...more

OCC determines FCA failure to investigate

OCC has published its findings in relation to a complaint against FCA. It found that FCA failed to investigate a complaint that consumers may have suffered detriment as a result of unauthorised and unqualified call handlers...more

OCC Issues Recovery Proposal for Institutions With Assets of $50 Billion or More

On December 17, the Office of the Comptroller of the Currency (OCC) requested comment on a proposed rule to establish enforceable guidelines for recovery planning by insured national banks, insured federal savings...more

Financial Services Weekly News - December 2015 #4

Regulatory Developments - FDIC Rule Amends Filing Requirements and Processing Procedures for Changes in Control - On Dec. 16 the FDIC announced the adoption of a final rule amending the FDIC's filing requirements...more

OCC Releases Quarterly Mortgage Metrics Report Showing Continued Improvement through Third Quarter of 2015

On December 14, the OCC released its quarterly Mortgage Metrics Report. The report shows continued improvement of the mortgage performance of first-lien mortgages during the third quarter of 2015. 93.9% of mortgages included...more

OCC Proposes Recovery Plans for Large Banks

On December 17, 2015, the Office of the Comptroller of the Currency (OCC) proposed guidelines establishing enforceable standards for recovery planning by certain large national banks, federal savings associations and insured...more

Cybersecurity & Other Risks: OCC Outlines Key Examination Areas for 2016

On December 16, 2015, the Office of the Comptroller of the Currency (OCC) issued its semiannual risk assessments for federally chartered financial institutions (the “OCC Report”). According to the Comptroller: “Strategic,...more

Final Rule Issued to Establish Minimum Margin Requirements for Non-Cleared Swaps and Non-Cleared Security-Based Swaps

On December 3, 2015, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Farm Credit Administration, and the Federal Housing...more

The Office of the Comptroller Provides Updated Guidance for Risk Assessment System

On December 3, 2015, the Office of the Comptroller of the Currency (“OCC”) provided updated guidance for its risk assessment system (“RAS”). The guidance (i) clarifies the relationship between RAS and the Uniform Financial...more

Third Party Service Providers Remain in the Spotlight

Yesterday, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (the “Semiannual Risk Perspective”). The Semiannual Risk Perspective covers “key issues facing banks, focusing on those...more

OCC Releases Semiannual Risk Perspectives Report

On December 16, 2015, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspectives report for the fall of 2015. The OCC’s Semiannual Risk Perspective report “addresses key issues facing banks,...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

FDIC: Providing Accounts and Other Services to Payday Lenders Is OK

Why it matters - Some bank vendors may cautiously smile when the FDIC makes a point that providing accounts and other services to payday lenders is fine, the Federal Deposit Insurance Corporation (FDIC) told banks by...more

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