The New Normal: Taking Responsibility for Your Vendors
Traditionally, the Office of the Comptroller of the Currency (OCC) did not require a national bank seeking to engage in non-depository, trust-only activities (a “trust-only bank”) to obtain Federal Deposit Insurance...more
In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - FIRM NEWS - FIRM PUBLICATIONS - MORTGAGES - BANKING - CONSUMER FINANCE - PRIVACY/DATA SECURITY - Excerpt from Privacy/Data...more
In This Issue: - RECENT CASES . Dodd-Frank Challenges Under the Administrative Procedure Act and Commodity Exchange Act . Preemption . Whistleblower Protection Under the Dodd-Frank Act . Arbitration...more
On January 1, 2013, the new regulations of the Office of the Comptroller of the Currency (the “OCC”) amending Part 16.6 of the OCC’s securities offering rules became effective. These rules govern the exemption from OCC...more
Today, the federal financial institution agencies (the FDIC, Fed, OCC, and NCUA), the CFPB, and the Federal Housing Finance Agency adopted a joint final rule to implement Dodd-Frank appraisal requirements for higher-priced...more
An insured federal depository institution may request a transition period to comply with the “push-out” requirements of section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”)...more
On January 4, the OCC issued a final rule that extends until July 1, 2013 the temporary exception for the application of its lending limits rule to certain credit exposures. In June 2012, the OCC issued an interim final rule...more
In This Issue: Leading the Past Week; Legislative Branch; Executive Branch; Miscellaneous; and International. Excerpt from Leading the Past Week - As was widely anticipated, President Obama announced that he...more
In This Issue: *Financial Industry Developments - OCC Guidance on Transition Periods under Section 716 of the Dodd-Frank Act - CFTC Reporting of Swap Transactions and Swap Dealer Registration - Department...more
On Thursday, January 3, 2013, the Office of the Comptroller of the Currency (the "OCC") provided guidance regarding requests for a transition period pursuant to Section 716 of the Dodd-Frank Wall Street Reform and Consumer...more
Section 716 of the Dodd-Frank Wall Street Reform and Consumer Protection Act prohibits the provision of federal assistance to an insured depository institution that is a swap dealer unless the swap activities of that...more
On January 3, the OCC issued guidance regarding requests for a transition period pursuant to Section 716(f) of the Dodd-Frank Act....more
On December 12, the OCC announced that it renewed the charter for the Mutual Savings Associations Advisory Committee (MSAAC). The MSAAC originally was chartered by the Office of Thrift Supervision, and responsibility for the...more
On November 26, the Fed, the FDIC, and the OCC, in conjunction with the Conference of State Bank Supervisions, issued “Interagency Statement on Section 612 of the Dodd-Frank Act: Restrictions on Conversions of Troubled...more
On November 26, the Federal Reserve Board, the FDIC, and the OCC, together with the CSBS, issued guidance on implementation of section 612 of the Dodd-Frank Act, which imposes restrictions on conversions of national banks and...more
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