Office of the Comptroller of the Currency

News & Analysis as of

OCC Increases Semiannual Assessment for Larger National Banks and Federal Savings Associations

On August 11, the Office of the Comptroller of the Currency (OCC) issued a final rule that increases the OCC’s semiannual assessment on national banks and federal savings associations (banks) with more than $40 billion in...more

Corporate and Financial Weekly Digest - Volume IX, Issue 32

In this issue: - SEC’s Office of Investor Education and Advocacy Releases Alert on Identifying Fraudulent Private Placements - ICE Futures U.S. Issues Amendments to EFRP Rule and FAQs - Consumer Financial...more

OCC Issues New Debt Sale Guidance

On August 4, the OCC issued Bulletin 2014-37, which provides new guidance on the application of consumer protection requirements and safe and sound banking practices to consumer debt-sale arrangements with third parties—e.g....more

FRB Interpretive Letter Grants Individual an Exemption from the Major Assets Prohibition of the Interlocks Act

The FRB recently issued an interpretive letter (the “FRB Letter”) in which the FRB granted an individual director (the “Director”) an exemption from the prohibition of the Depository Institution Management Interlocks Act (the...more

OCC Issues Bulletin That Discusses the Characteristics of and Supervisory Considerations Concerning Mutual Federal Savings...

On July 22, 2014, the OCC issued a bulletin (OCC Bulletin 2014-35, the “Bulletin”) in which the OCC describes the special characteristics of mutual federal savings associations (“Mutual FSAs,” and, collectively with...more

Orrick's Financial Industry Week in Review

Fed Issues Report on the Economic Well-Being of U.S. Households - On August 7, the Fed provided a snapshot of the self-perceived financial and economic well-being of U.S. households and the issues they face, based on...more

OCC Publishes Final Rule that Revises the Risk-Based Capital Definition of Eligible Guarantee for Advanced Approaches Banks

The OCC, the Fed, and the FDIC have published a final rule that revises the advanced approaches risk-based capital rules by removing the requirement that only guarantees provided by certain counterparties are eligible for...more

OCC consumer protection standards in new Bulletin may influence CFPB Debt Sales Examinations of Banks

As noted in our recent Alert, the Office of the Comptroller of the Currency (OCC) has issued Bulletin 2014-37 on Consumer Debt Sales (the “Bulletin”). The Bulletin addresses the application of consumer protection requirements...more

New OCC Guidance on Debt Sales

On August 4, 2013, the Office of the Comptroller of the Currency (“OCC”) released new guidance to (Bulletin 2014-37) regulated entities on the application of consumer protection requirements and safe and sound banking...more

CFPB releases more overdraft program data as a prelude to likely rulemaking

The CFPB moved closer to likely rulemaking on overdraft programs with the release late last week of a new report entitled “Data Point: Checking account overdraft.” The report is based on account-level and...more

OCC Report Highlights Risks Linked to Evolving Cyberthreats

According to the latest semi-annual risk report issued by the U.S. Office of the Comptroller of Currency (OCC), new methods of money laundering and a growth in both the volume and sophistication of electronic banking fraud...more

Dodd-Frank News: July 2014 Dodd Frank Wall Street Reform and Consumer Protection Act Update

In This Issue: - Recent Cases ..RESPA ..FDCPA ..TCPA ..FCCPA & FDCPA ..TILA - In The News ..CFPB to Begin Collecting Complaints Regarding Prepaid Cards ..CFPB Proposes Letting...more

OCC Report Lists Key Risks For Review In Upcoming Examinations

Highlighting the operational, strategic, and compliance risks confronting financial institutions, the Office of the Comptroller of the Currency (OCC) published its “Semiannual Risk Perspective” report in late June based on...more

FDIC Proposes Changes to Assessments Rule

On July 15, the Federal Deposit Insurance Corporation (FDIC) proposed (1) to revise the ratios and ratio thresholds for capital evaluations used in its risk-based deposit insurance assessment system (the FDIC stated this was...more

FDIC Proposes Rule to Revise Deposit Insurance Assessments to Reflect the Basel III Capital Rule

The FDIC issued a notice of proposed rulemaking (the “Proposed Rule”) that would revise the FDIC’s risk-based deposit insurance assessment system to reflect the final Basel III capital rule (the “Final Capital Rule”) adopted...more

Financial Regulatory Developments Focus - July 2014 #3

In this issue: - Derivatives - Compensation - Bank Prudential Regulation and Regulatory Capital - Recovery & Resolution - Credit Ratings - Insurance - Financial Services...more

Main Street Cashes $3.1 Billion in Checks from Wall Street

With the mortgage crisis almost a decade in the rear-view mirror, some harmed homeowners are just now starting to see reparations for the transgressions of the country’s largest financial institutions. ...more

Financial Regulatory Developments Focus - July 2014 #2

In this issue: - Derivatives - Regulatory Capital - Recovery & Resolution - Financial Services - Consumer Protection - Enforcement - People - Events -...more

Orrick's Financial Industry Week in Review

New York's Highest Court Will Review First Department Decision on RMBS Putback Statute of Limitations - On June 27, the Court of Appeals for the State of New York agreed to review the First Department's December 2013...more

Digital Commerce & Payments Update

In this Issue: - Insights & Trends ..The Future of Regulation in the Digital Economy - Virtual Currency ..GAO Urges CFPB Participation In Virtual Currency Working Groups ..Trade Group White Paper...more

FFIEC Establishes Cybersecurity Web Page and Announces Commencement of Cybersecurity Assessment Program of Community Banks

The Federal Financial Institutions Examination Council (the “FFIEC”) announced that it had established a web page on cybersecurity (the “Web Page”), which is designed to serve as a central repository for current and future...more

Observation 1.0.1 on the Volcker Rule: With Summer Comes the First Wave — Of Guidance

A set of frequently asked questions, developed jointly and adopted in substantively identical form by the federal banking agencies (the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB) and the...more

OCC Examines Risks Facing National Banks and Federal Savings Associations

On June 25, the OCC released a report presenting its findings on the risks facing national banks and federal savings associations. ...more

OCC Report Highlights Cybersecurity, BSA-AML, Indirect Auto Underwriting Concerns

On June 25, the OCC published its semiannual risk report, which provides an overview of the agency’s supervisory concerns for national banks and federal savings associations, including operational and compliance risks....more

Pom v. Coke Will Impact Financial Services Too

Law 360, New York (June 23, 2014, 11:22 AM ET)--Legal and compliance departments, take note: the U.S. Supreme Court’s recent decision in Pom Wonderful LLC v.Coca-Cola Co. confirms that even i fan institution’s conduct meets...more

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