Office of the Comptroller of the Currency

News & Analysis as of

Orrick's Financial Industry Week In Review

Financial Industry Developments - Class Action Against Lending Club and WebBank Headed to Defeat - On Monday, January 31, 2017, a federal district court in the Southern District of New York granted a motion to...more

New IRS Memo Concludes Benefits Paid by Fixed-Indemnity Health Plans May Be Taxable Income

On January 20, 2017, the Office of Chief Counsel of the Internal Revenue Service (IRS) issued a Memorandum on the tax treatment of benefits paid by fixed-indemnity health plans. In the Memorandum, the OCC concludes that...more

Trump’s call to ‘rationalize’ federal financial regulation could threaten U.S. dual banking system

As a prelude to “doing a big number on Dodd Frank,” President Trump issued an Executive Order February 3 designating “core principles” of financial regulation, which include a directive to “rationalize the Federal financial...more

Orrick's Financial Industry Week In Review

Financial Industry Developments - Class Action Against Lending Club and WebBank Headed to Defeat - On Monday, January 31, 2017, a federal district court in the Southern District of New York granted a motion to...more

The OCC Publishes Final Rule Adjusting Civil Money Penalties for Inflation

On January 27, 2017, the Office of the Comptroller of the Currency (the “OCC“) published a final rule amending its rules of practice and procedure for national banks and in adjudicatory proceedings for federal savings...more

The Trump Administration: President Trump Issues Executive Actions on Dodd-Frank and the DOL Fiduciary Rule

On February 3, 2017, President Trump signed two executive actions intended to provide a framework for scaling back the Dodd-Frank Act (“Dodd-Frank Act”) and rescinding or revising the Department of Labor’s “fiduciary rule.”...more

Financial Services Weekly News - February 2017

Editor's Note - President Trump Signs Executive Order to Reduce Regulation and Control Regulatory Costs. On January 30, President Trump signed an executive order (Executive Order) designed to reduce the regulatory...more

New York State Department of Financial Services Superintendent Submits Comment Letter to US Office of the Comptroller of the...

NYSDFS Superintendent Maria T. Vullo submitted a comment letter opposing the OCC’s proposal to create a new national bank charter for FinTech companies. Vullo noted that a one-size-fits-all federal charter will not work to...more

US Office of the Comptroller of the Currency Launches Web-Based System for Licensing

The OCC launched the agency’s new web-based Central Application Tracking System (CATS). The system will assist authorized national banks, federal savings associations and federal branches and agencies with drafting,...more

NY Department of Financial Services Joins Opposition to the OCC’s Proposed FinTech Charter

On January 17, 2017, Maria Vullo, the Superintendent of the New York State Department of Financial Services (NY DFS) sent a letter to the Office of the Comptroller Currency (OCC), opposing the OCC’s proposed special purpose...more

Federal Banking Agencies Extend Comment Period for Advance Notice of Proposed Rulemaking on Enhanced Cyber Risk Management...

The Federal Reserve, the OCC and the FDIC extended the comment period on an advance notice of proposed rulemaking on enhanced cyber risk management standards...more

US Office of the Comptroller of the Currency Releases Semiannual Risk Report

The US Office of the Comptroller of the Currency released its Semiannual Risk Perspective for Fall 2016, which highlights key risks facing national banks and federal savings associations. The report highlighted that strategic...more

A Potentially Promising Approach to Regulation of FinTech or Should the U.S. Adopt a Regulatory Sandbox?

The Office of the Comptroller of the Currency (“OCC”) recently published a proposal to bring emerging financial technology (“FinTech”) companies within the scope of the agency’s jurisdiction. The proposal is useful as part of...more

NYDFS, American Bankers Association Weigh In On OCC Fintech Charter Proposal

The New York State Department of Financial Services (NYDFS) has come out strongly against an Office of the Comptroller of the Currency (OCC) proposal to grant national bank charters to financial technology (fintech)...more

Rock and a Hard Place: Banks In Search of Compliance Amid Diverging Regulatory Regimes

Last year was the first that national banks and federal savings associations subject to supervision by the Office of the Comptroller of the Currency (“OCC”) were armed with a sense of the agency’s regulatory expectations when...more

Orrick's Financial Industry Week In Review

Financial Industry Developments - Federal Reserve Board Announces Finalized Rule Adjusting the Board's Maximum Civil Money Penalties - On January 18, 2017, the Federal Reserve Board announced that it was adjusting...more

Financial Services Weekly News - January 2017 #3

Editor's Note - Opposition Emerges to OCC FinTech Charter. In advance of the deadline to submit comments to the Office of the Comptroller of the Currency’s (OCC) paper proposing a federal FinTech charter, the Conference...more

Emerging Trends Newsletter - Q4

The Volcker Rule Under the Trump Administration - The so-called Volcker Rule—named after Paul Volcker, a former chairman of the Federal Reserve Board—was part of the Dodd-Frank Wall Street Reform and Consumer Protection...more

Should Your Fintech Company Apply for an OCC Charter

During this webinar, panelists addressed whether a fintech company should apply, and what is involved in obtaining the proposed fintech OCC charter. These are the PowerPoint slides from the webinar. Key topics...more

Agencies Extend Comment Period for Advance Notice of Proposed Rulemaking on Enhanced Cyber Risk Management Standards

On January 13, 2017, the Federal Reserve Board, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation changed, from January 17, 2017 to February 17, 2017, the deadline for comments “for...more

Algorithms and bias: What lenders need to know

The algorithms that power fintech may discriminate in ways that can be difficult to anticipate—and financial institutions can be held accountable even when alleged discrimination is clearly unintentional....more

Financial Services Weekly News - January 2017 #2

Editor's Note - In This Issue.The SEC and FINRA released their examination priorities for 2017; the SEC’s Division of Investment Management issued an interpretative letter that would permit brokers to charge their own...more

Your Daily Dose of Financial News

Deutsche Bank and the DOJ have put the finishing touches on the deal to resolve the investigation into DB’s role in its sale of toxic RMBS. The bank will fork over $7.2 billion in total, including a $3.1 billion civil penalty...more

2017 Resolutions for Community Banks: A Focus on Cybersecurity

In December 2016, Thomas Curry, the Comptroller of the Currency, stated that cybersecurity was the single greatest systemic threat to our financial system. He was not being hyperbolic. Cybersecurity should be on...more

Orrick's Financial Industry Week In Review

Financial Industry Developments - Prohibition on Dealing or Investing in Industrial or Commercial Metals - On January 3, 2017, the Office of the Comptroller of the Currency (the "OCC") finalized a rule that...more

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