News & Analysis as of

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

Financial Services Weekly News - January 2017

Editor's Note - In This Issue. The NYDFS revised its proposed cybersecurity regulations, the FDIC sought comment on its new de novo bank deposit insurance handbook, federal banking agencies finalized streamlined call...more

Annual Asset-Size Threshold Adjustments for Small and Intermediate Small Banks

On December 29, 2016, the Office of the Comptroller of the Currency, the Federal Reserve System and the Federal Deposit Insurance Corporation amended their Community Reinvestment Act (CRA) regulations to adjust the asset-size...more

Trump transition team releases names of additional CFPB landing team members

The Trump transition team has released the names of three more individuals who will be members of the CFPB landing team.  “Landing teams” are members of the incoming president’s transition team tasked with gathering...more

DOJ Files Consent Order Against Union Savings Bank, Guardian Savings Bank

The U.S. Department of Justice (DOJ) has filed a consent order against Union Savings Bank and Guardian Savings Bank to resolve redlining allegations. The complaint alleges that the banks violated the Fair Housing Act (FHA)...more

Regulators’ Christmas Gift to Banks: 18-Month Examination Cycle

Earlier this month, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation issued final interagency rules which will reduce regulatory...more

Federal Banking Agencies Finalize an 18-Month Examination Cycle for Small Banking Institutions

On December 12, 2016, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board and the Office of the Comptroller of the Currency (OCC) finalized rules that generally allow well-capitalized and well-managed...more

US Federal Banking Agencies Finalize Rule Expanding Examination Cycle for Small Insured Depository Institutions and US Branches...

The US Federal Deposit Insurance Corporation, Federal Reserve Board and Office of Comptroller of Currency issued interagency final rules that increase the number of small banks and savings associations eligible for an...more

OCC Final Receivership Rule Paves Way for Special National Bank Charter

The Office of the Comptroller of the Currency ("OCC") announced on December 20, 2016 that it is adopting a final rule to implement provisions of the National Bank Act that provide the legal framework for receiverships for...more

Alert: Office of Comptroller of Currency Seeks Comment on Proposed “Fintech Charter”

The Office of the Comptroller of the Currency ("OCC") announced on Friday, December 2, that it seeks comments on whether it should grant "special purpose" national bank charters to financial technology companies. Some of the...more

OCC Issues Final Rule on Receiverships for Uninsured National Banks

On December 20, the OCC issued its Final Rule on receiverships for uninsured national banks which implements the National Bank Act’s statutory framework for uninsured bank resolution....more

OCC Adopts Final Rule On Receiverships for Uninsured National Banks

On December 19th, the Office of the Comptroller of the Currency issued a final rule regarding how it will address receiverships of special purpose national banks which do not have deposits insured by the Federal Deposit...more

Financial Services Weekly News - December 2016 #2

Editor's Note - In This Issue. While we eagerly await its decision on interest rates, the Fed had a busy week, granting a Volcker Rule extension for illiquid funds, issuing a joint final rule with the FDIC and the OCC...more

Federal Banking Agencies Seek Comment on Enhanced Cyber Risk Management Standards for Large Banks

To address the increasing risk of technology failures and cyber-attacks affecting the largest banking organizations, an advance notice of proposed rulemaking titled Enhanced Cyber Risk Management Standards (the ANPR) was...more

"Federal Regulator Signals Willingness to Grant National Bank Charters to Fintech Companies"

On December 2, 2016, the Office of the Comptroller of the Currency (OCC) announced its willingness to entertain applications from financial technology (fintech) companies for special purpose national bank charters. In recent...more

US Comptroller of the Currency Will Offer Limited Purpose National Bank Charters to Fintech Companies

The Comptroller of the Currency, Thomas Curry, announced on December 2, 2016, that the Office of the Comptroller of the Currency (OCC) intends to move forward with issuing limited purpose national bank charters to financial...more

OCC Explores Special Purpose National Bank Charter for Fintech Companies

On December 2, 2016, the Office of the Comptroller of the Currency (“OCC”) announced its plans to move forward with a proposal to consider applications from financial technology (“fintech”) companies to receive charters as...more

Office of the Comptroller of Currency to Issue Charters to Fintech Companies

On Friday, December 2, the Office of the Comptroller of Currency (OCC) announced that it would start considering applications for special purpose national bank charters from financial technology (fintech) companies. The OCC...more

OCC to Consider Special Charter Applications for Fintech Companies

On December 2, 2016, Comptroller of the Currency Thomas J. Curry announced that the OCC will move forward with considering granting federal charters—under the OCC’s existing authorities—to financial technology companies. ...more

New Rules of the Cyber Road: Federal Banking Regulators Seek Comment by January 17, 2017 on Proposed Cybersecurity Regulations

Continuing the trend of recent years, cybersecurity has remained at the top of the regulatory agenda for several federal and state agencies. For financial institutions, keeping track of the dizzying array of proposed...more

OCC Announces Special Purpose National Bank Charter for FinTech Companies

On December 2, 2016, Comptroller of the Currency Thomas Curry confirmed that the agency will begin considering applications from FinTech companies to become special purpose national banks, saying that the OCC will charter...more

OCC Will “Move Forward” With Federal FinTech Charter

The Office of the Comptroller of the Currency (the OCC) plans to consider applications from companies engaged in financial technology—or FinTech—activities to operate through a national bank charter and has released a paper...more

Cybersecurity Risk: Latest Guidance from Bank Examiners

The Office of the Comptroller of the Currency has indicated in a recent bulletin that its examiners will gradually incorporate a Cybersecurity Assessment Tool into its examinations of national banks and other institutions...more

[Webinar] Meritas Capability Webinar - Latest Developments in Financial Services Law - December 14th, 1:00pm CST

This webinar will provide information on recent developments in financial services law over the past year....more

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