News & Analysis as of

Office of the Comptroller of the Currency Compliance

WilmerHale

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

WilmerHale on

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

Goodwin

10 Considerations for Fintechs Partnering with Community Banks

Goodwin on

As banking and technology become more integrated, banks are increasingly partnering with fintechs to expand their customer offerings. The rapid rise of these partnerships has generated questions for both banks and fintechs on...more

Alston & Bird

CFPB and Other Federal Agencies Finally Adopt AVM Rule

Alston & Bird on

What Happened? On June 20, 2024, a group of federal regulators published a rule addressing for the use of automated valuation models (AVMs) in mortgage origination and secondary market transactions....more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - April 2024

Editor's Note The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

GeoDataVision

Climate Risk, the emerging risk

GeoDataVision on

This episode of the podcast, focusing on climate risk as an emerging regulatory compliance issue, features a dialogue between Len and Dean. They discuss how climate-related risks, especially in the financial sector, have...more

Bradley Arant Boult Cummings LLP

A Closer Look at the CFPB’s “Enhanced” Supervisory Appeals Process

On February 16, 2024, the Consumer Financial Protection Bureau (CFPB) announced what it heralded as a significant update to its Supervisory Appeals Process. The first of its kind since 2015, this revision introduced a...more

The Volkov Law Group

Sterling Bank’s ex-General Counsel hit with OCC Cease-and-Desist over Longstanding BSA/AML Shortcomings

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The Treasury Department’s Office of the Comptroller of the Currency (“OCC”) has taken action against the former General Counsel of Michigan-based Sterling Bank and Trust in the agency’s latest action against an individual...more

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

NAVEX

How to Build a Good Risk Assessment Process

NAVEX on

Risk assessments are one of the most important tasks a compliance officer performs – and also one of the most confounding. How do you keep assessing your organization’s risks in a disciplined, methodical manner, when the...more

Womble Bond Dickinson

OCC Issues New Version of the “Lease Financing” Booklet of the Comptroller Handbook

Womble Bond Dickinson on

On September 27, 2023, the Office of the Comptroller of the Currency (OCC) issued Version 2.0 of the Lease Financing booklet of the OCC’s Comptroller Handbook, which replaced Version 1.0 published in August 2014 and updated...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Adams and Reese LLP

OCC Publishes Revised Examination Procedures Addressing Telephone Consumer Protection Act

Adams and Reese LLP on

On November 1, 2023, the Office of the Comptroller of the Currency (OCC) published a revised interagency examination procedure to address updates to the federal Telephone Consumer Protection Act (TCPA). Although TCPA...more

Holland & Knight LLP

Agency Guidelines Confirm That Climate-Related Financial Risk Is Real

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corp. (FDIC) (collectively, the Agencies) on...more

Moore & Van Allen PLLC

The Federal Reserve, FDIC and OCC Issue Final Guidance on Risk Management in Third-Party Relationships: Moore & Van Allen

On June 6, 2023, the Board of Governors of the Federal Reserve System (the Federal Reserve), the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC, and collectively with the...more

Pillsbury Winthrop Shaw Pittman LLP

Bank-Fintech Partnerships and Fair Lending: Top Areas at Risk for Government Scrutiny

The Federal Deposit Insurance Corporation (FDIC) recently published a consent order issued against Cross River Bank that alleged the bank’s fair lending program’s noncompliance and weaknesses in its oversight of fintech...more

The Volkov Law Group

TD Bank Eats $225 Million Termination Fee After AML Failures Doom Merger

The Volkov Law Group on

How much is an effective Anti-Money Laundering (“AML”) Compliance Program Worth? For Toronto-Dominion Bank (“TD”), the answer is at least $225 million––the amount that TD must now pay to First Horizon Bank, after backing...more

Dechert LLP

Fair Lending Compliance for Mortgage Lenders: An ESG Approach

Dechert LLP on

Mortgage lenders of all sizes are paying closer attention to environmental, social and governance (“ESG”) issues as they face inquiries from their investors and customers as well as increased scrutiny from regulators. Given...more

Paul Hastings LLP

Top PHive Crypto Enforcement Notes: December Edition

Paul Hastings LLP on

Well, it was another quiet month in crypto . . . Not. We are still watching the tsunami play out in real time, as governments and the crypto market react to another seismic shift in the crypto landscape....more

Venable LLP

Bank Provider of BaaS Dinged by OCC; Blueprint for Fintech Partnerships?

Venable LLP on

​​​​​​​A recent action by the Office of the Comptroller of the Currency (OCC) highlights how banks need to ensure that they have robust compliance programs for managing risks posed by their banking as a service (BaaS)...more

Moore & Van Allen PLLC

Risks Associated with Cryptocurrency Activities Continue to be Top-of-Mind for Federal Banking Regulators

Moore & Van Allen PLLC on

For those tracking developments impacting the crypto-asset space, the summer has been far from slow and leisurely. Multiple industry alerts flow daily with news of new legislative proposals, enforcement actions, and other...more

Latham & Watkins LLP

Federal Reserve Issues Cryptoasset Engagement “Rules of the Road” for Its Supervised Banking Organizations

Latham & Watkins LLP on

The Federal Reserve is taking measured steps to better understand the types of cryptoasset-related activities contemplated by its supervised banking organizations. On August 16, 2022, the Board of Governors of the...more

Buchalter

OCC Highlights Banks’ Compliance Staffing Issues, Even as Regulators Place More Compliance Demands on Banks and Place Executives...

Buchalter on

In its recent Semiannual Risk Perspective, the Office of the Comptroller of the Currency (OCC) has highlighted the difficulties banks face finding adequate numbers and quality of hires for compliance oversight. While there...more

Harris Beach PLLC

Recent Enforcement Actions Indicate Heightened Scrutiny of BSA/AML Compliance and Digital Assets

Harris Beach PLLC on

Recent enforcement actions against banks indicate a new regulator emphasis on digital assets and Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance. Last year, Anchorage Digital Bank (Anchorage)—formerly Anchorage...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2022

Federal Banking Agencies Issue CRA Modernization Proposal The federal banking agencies have jointly issued a proposed rule that would modernize their regulations that implement the Community Reinvestment Act (the “CRA”). The...more

Moore & Van Allen PLLC

Acting Comptroller Hsu Suggests a Potential Path Forward to Address Identified Gaps in the Regulatory Resolution Framework for...

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In the fourteen years since the 2008 financial crisis, significant actions have been taken by Federal banking agencies to make the largest financial institutions more resilient and less likely to fail and to require planning...more

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